Discussion Assignment Example | Topics and Well Written Essays - 250 words - 41

Discussion - Assignment Example It is also worth mentioning that both the knife and electric water pump require to be operated manually and the operator has to do some ‘work’. Thus, in this case, the issue of laziness doesn’t arise at all. According to the BLS American Time Use Survey, A.C. Nielsen Co. conducted in the first quarter of 2012, the average American spends slightly over 5 hours a day watching television. While on the surface he figure looks staggering, it is important to note that the figure takes into account people beyond retirement age who while away entire days in care centres glued to the screen of television. The bulk of he productive population would typically watch television only when having dinner and during weekends. To them, this is more like a hobby than a lifestyle. As with regards to the use of technology and it making us more lazy,nothing can be farther from the truth. It is a matter of perception, which has evolved over time. Fifty years ago the word â€Å"hardworking† was directly proportional to the muscle one possessed and the amount of sweat shed and effort spent in the process. Today, one could achieve much more using by far less energy. A housewife could use tools like washing machine, dishwasher and vacuum cleaner and make her house sparkling clean within a short period of time. Without these, the same housewife would take a whole day performing the same tasks, and probably wouldn’t do it as well as he machines would. To sum it all up, I’d like to remind us that machines are tools meant to assist us in performing tasks and making our lives more comfortable. They are here not to replace us or do our jobs for us, but as tools at our disposal. Life would not be as comfortable or well-advanced were I not for machines. Let us embrace them and appreciate their usefulness in our daily

Effect of Docosahexaenoic Acid in Dog Food Essay

Effect of Docosahexaenoic Acid in Dog Food - Essay Example Dog foods are designed to give the proper nutrition and specific requirements of these pets. Recently, the importance of Docosahexaenoic acid (DHA) and fatty acids were highlighted by dog food makers. Fish oil, a rich source of fatty acids, was demonstrated in various uses such as improving dull coat of dogs, remedy for allergies, relieving inflammation, supporting brain and eye development. While there are specific studies that scientifically explain the functions of individual fatty acids, effects of doses of fatty acids, specifically DHA, in dog foods are not clear. DHA was proven to have beneficial effects on the brain development of young dogs and on the retina of growing and ageing dogs. There are claims of such benefits with the use of some dog foods but the methodology and results were poorly documented. This proposal aims to determine the effects, if there are any, and the extent of effects of DHA as a component of dog food on the health and intelligence of dogs. The objectives of this proposal includes 1) to determine the effects of different levels of DHA in commercial dog food (Hill's Science Plan) on learning and training ability of dogs, 2) to determine the effects of DHA in dog food through health indicators such as dog fur or coat and c) to determine the effects of DHA in dog food on eye functions of dogs. Fatty acids are forms of polyunsaturated f... Those that they cannot produce but are instead obtained through external sources such as food are called essential fatty acids (Ackerman 1148). Omega-3 fatty acids include Alpha-linolenic acid (ALA) deficiency of which is related to skin disease development, Eicosapentaenoic acid (EPA) which is involved in vasoconstriction and related cardiac function and Docosahexaenoic acid (DHA) which is essential for brain and retinal functions. ALA is convertible into EPA and EPA is considered a major mover of the omega-3 fatty acids and is found in the cell membrane (Leaf 197-198, Kenny et.al. 660, Giron et.al.198). Omega-6 fatty acids on the other hand include Linoleic acid (LA) which is found in the skin, Gamma linolenic acid (GLA) and Dihomo-gamma-linolenic acid (DGLA) which are forms of LA, and Arachidonic acid (AA) which is involved in prostaglandin synsthesis. LA can be transformed into GLA. DGLA can be converted from GLA in the skin. LA is vital for optimizing skin's water permeability. AA in large amounts is detrimental to other fatty acids (Pitas 470, Campbell & Roudebush 82). DHA Docosahexaenoic acid (DHA) is a major constituent of brain phospholipids and serves an important function in sustaining structural and functional properties of membranes. DHA is coupled in glycerophospholipids generally with palmitic acid and stearic acid and with an additional long-chain polyunsaturated fatty acid which builds up in phosphatidylethanolamines. Adequate supply of DHA has been postulated to promote maximum neurological growth, information processing, the capacity to conduct electrical stimuli of nerve cells, and cognitive ability. There is consensus among experts that mammalian brain produces its own DHA during particular stages of intrauterine and

Media Representation of Violent Crimes | Race

Media Representation of Violent Crimes | Race The thesis of the paper is, the media representation of violent crimes by African Americans. It has indeed been proven that the media portrays a very negative image on violent crimes as perpetrated by black Americans and this to a large extent ÂÂ  impacts on the law, regulations, and public perceptions on the violent crimes. For instance, a violent crime such as rape has been painted as a grim reality that all of us need to be aware. This has had the effect of even influencing the way law makers perceive rape. It has eventually led to stringent laws being developed to deal with the crime by the blacks. The most notable law in the US history was the one restricting the way in which the sex offender moves through the sex offenders restrictions Act. This paper will succinctly focus on the various media perceptions about the violent crimes and especially the way the media represents violent crimes thus influencing the public perception of the same. The result of the media representation of violent crime by black Americans has been more strict measures being taken that is aimed at curbing the propagation of such crime. Previously as noted, such crimes were often silent and thus the public did not know much about the violent crimes. However, due to the media representation of such violent crimes, crimes such as assault, wife battery have now become more pronounced more than ever. It has therefore become clearly known that the violent crimes are treated with more weight as a result of increased knowledge by the public especially of the violent crimes (Lind, 2004). The media has often been faulted for propagating violence in many forms. The violence that is portrayed by the media actually encourages the vice to continue instead of helping to educate the public in order to avert future problems. It was revealed that most of the news that sells in the media and attracts much attention is news pertaining to violent crimes by the black Americans. We would often turn the volume of our television or radio sets up in order to listen to some shoot out news in which a gangster or police officer was killed or more so to listen to testimonies by witnesses in a rape or robbery case. The body of this paper shall consider the impacts of the media representation on violent crimes by the black Americans. Indeed, criminology theories are often contemporary theories and not standalone theories as perceived by most scholars (Croteau Hoynes, 2000). The theories help to explain the rationale behind what most criminology researchers put forth. In this paper, we shall explain how the media representation of violent crimes impacts on the law and generally on the US regulations in light of the classical criminology theory. Several researchers have explored the media representation of various phenomena, with very few suggesting that the media rarely imparts positive impact on the law and public perceptions on violent crimes. Furthermore, it is imperative to note that the media indeed influences different aspects of the law by painting a stern picture of the violent crimes through emphasizing on the consequences of such crimes and the reality in terms of victims that are left after the perpetration of such violent crime. We shall first begin by looking at the positive impact that the media has on its representation of violent crimes to the society at large. Firstly, it is important to note that most of the violent crimes go against the societal values and core beliefs. This has indeed made the media to point out the reality behind such violent crimes. It is often common to see the media emphasizing on the effects of such violent crimes such as rape. Sometimes, the media even uses real victims to succinctly convey the message. This has left several impacts as insinuated by several researchers. A lot of research has been done to determine the spate of media influence on the violent crimes to the society. Critics suggest that the media has made the publics perception about violent crimes by the black Americans to change. This has observably changed for the worse. Consequently, research has shown that violent crimes could be effectively be dealt with at a higher level by the law enforcement agencies. What is most important is the awareness by the general public. The media therefore plays a pertinent role in fostering this. Maguire, Morgan and Reiner (2007) reveal that the picture painted by the media on violent crimes by black Americans such as rape has made the law makers to realize how serious the violent crime can affect the society. In particular, law makers have become more aware of the factors that actually lead to the propagation of violent crimes so that they may effectively pass laws that will ensure that the activities that lead to the violent crime or at least contribute to the violent crime are kept in check. For instance, rape in the media was portrayed as emanating from the activities of idle boys and the youth who apparently did not have anything to do. This in turn made the law makers to seek ways of preoccupying the youth in a more constructive manner. Therefore, the youth development projects were formed to take care of the needs of the youth. Apparently, the youth in California were found to be engaged in various activities (Greer, 2003). Some of these activities were not so construc tive as such. Therefore, the law makers formulated laws that effectively ensured that the youth were well occupied. This therefore meant that the youth could be engaged in educational as well as community activities. Consequently, the media representation of the violent crimes made it easier for the public to perceive violent crime as an emerging crime that was previously hidden under the pillow. This therefore apparently enabled crimes such as assault and domestic violence to emerge and become topical issue in the media as well as in the public forum. The result of this therefore was that the public became more aware of the effects of violent crime, specifically, domestic violence and assault as well as rape. Thus, the media has been extremely successful in exposing such crimes to the public knowledge. The public has responded by being more vigil in terms of fighting the crime through community oriented initiatives. The media in conjunction with the police bring to the attention of the public certain crimes that they would have otherwise been ignorant of. The media continues to be ardent in exposing criminal activities and syndicates. The most recent syndicate to be exposed was that of track it which apparently fleeced unsuspecting citizen of millions of dollars. Apparently some of the renowned black Americans were connected to this syndicate which was accused of defrauding the public of their innocently earned money. This way, the media ensures that unscrupulous business entities are busted and their licenses ceased. Lind (2004) suggests that the spate of crime by the Black American is on the rise and if nothing is done to address the root cause, then it is likely that this could escalate beyond repair. The society at large subsequently instigated steps that were meant to curb the growing trends in the violent crimes. The trends of such violent crimes can thus be monitored and steps taken by the law makers and the public to mitigate it. This has therefore had the positive effect of reducing the incidences of violent crime within the society setting. Stenson and Sullivan (2001) insinuate that the media alert on violent crime has helped the public to specifically improve their response to such crimes thus reducing the occurrences of such crimes. In particular, the public has become more receptive in helping the police to monitor such kinds of crime through the community oriented policing modules. In her book, Lind (2004) reveals that the media indeed portrays race as a contributory factor towards the violence as seen in most of the scenes of violence. The black Americans are particularly faulted for being boisterous in terms of their propensity to propagate violent crimes. In the United States, nearly half of those individuals who are incarcerated are black Americans. This indicates a worrying trend that must be mitigated. The media also revealed that the state of Texas had been coarsely affected by the increase in the number of inmates who had been incarcerated by the federal government. The federal government on the other hand has the relevant statistics necessary to formulate the necessary measures aimed at averting the vice of violent crimes. Media is the mouthpiece of the society. The society has come to believe the media in most of the aspects pertaining to the society in general. Therefore, it is the onus of the media to ensure that they consistently inform the public of the various happening and to subsequently effectively warn the public of a growing trend. The public is therefore receptive of such happenings that will affect its perceptions as propagated by the media. More often, the media simply According to Davies, Francis and Greer (2007), crime occurs where the benefits outweigh the costs. This is the definition of the classical theory of criminology. The classical theory of criminology therefore goes ahead to state that when people are after self interest, with the lack of presence of punishment that is tangible or even intangible, crime occurs. Therefore what this means is that the violent crime occurs as a result of lack of knowledge by the general public. This also means that the media serves as an important vessel in mitigating crime by the blacks through effectively monitoring crime prevalence. Media has been very successful due to its ability to reach multitudes of people at the same time thus ensuring that information is conveyed to masses. The law makers also serve to formulate laws that ensure violent crime by black Americans is kept in check (Miller, 2003). This could not be possible without the contribution of the media in highlighting the areas of violent cri me that the law makers need to focus on. Moreover, this will have a ripple effect in ensuring that the violent crime does not continue and is effectively put under check. The classical theory also states that crime, and violent crime for that matter is a free will and upon an individuals choice. The people who propagate crime are therefore people of sane mind, body and spirit. Therefore, what this means is that violent crime by the black Americans has indeed been a matter of choice. According to Muncie and Wilson (2004) issues regarding choice can only be eliminated through publicity and increasing awareness. This as earlier mentioned can best be done by the media. The media has for ages painted a grim picture of violent crime and been against it in totality. This has therefore meant that the violent crime incidences have been shunned by the society in general and thus led to a decline in cases involving violent crime. On the other hand, the media has negative impact in terms of the image that it paints in relation to the violent crime on the society as well as the impacts that it has had on the laws and regulations. Greer (2003) notes that the media has overblown the issue of violent crime beyond proportion thus making it difficult for the determination of the true magnitude of the violent crime and the extent to which it should be shunned The consequences of this have been thorough in terms of influencing the way law makers perceive violent crime. It is also true according to the classical theory of criminology that the violent crime by black Americans is the brain child of a society that lacks direction. This is indeed a wakeup call for the law makers and the relevant administrators to take up the challenge and rise up to the occasion as pertains to ensuring that the perpetrators of violent crime are dealt with. Maguire, Morgan and Reiner (2007) concur by suggesting further that the law makers have accorded strict punishment to some of the violent crimes such as assault thus putting the perpetrators who may have acted under self defense to thorough capital punishment. Similarly, the law makers have been very mean in terms of passing amendments meant to reduce the punishment accorded to the perpetrators. Critics suggest that the best form of punishment that would be suitable for the perpetrators of violent crimes would be serving several years behind bars and then community service for a couple of years (Davies, Francis Greer, 2007). The media representation of violent crime by blacks Americans has therefore left very stern action taken by the law makers. Furthermore, the public at large have been left with a very bad perception. Greer (2003) suggests that the public now view most of the violent crimes by the black Americans as gross. This has made the public to take very stern action while dealing with the perpetrators of such violent crime such as rape. The public has therefore become autonomous in terms of judging a person suspected to have perpetrated the violent crime and subsequently played the part of the court or judicial system. This has made the public to take law into their own hands and set ablaze or even brutally killed the perpetrators. The classical theory of criminology further supports the fact that violent crime is caused by an individuals volition. This volition should be turned for the good of the individual through encouraging good behavior within the community and thus effectively rehabilitating a violent crimes perpetrator. Stenson and Sullivan (2001) suggest that the media has effectively denied the perpetrators of violent crime the chance to change and be part of the society. This theory further supports a no-crime environment through solving crime from its roots. Therefore, the law enforcement agencies will have a very smooth ride due to the implementation of these theories. The other important negative impact of the media representation of violent crime by the black Americans has been that individual especially the teenagers who are apparently below the age of majority have been exposed to violence at a tender age. The media has therefore succeeded in changing the perception of such age groups of violent crimes since they view this as a normal happening and therefore they grow up knowing that violent crime by the black Americans is part of the society. Muncie and Wilson (2004) suggests that it is usually very difficult to change such perception. In fact, the teenagers perception of violent crimes by the black Americans is so grim such that some of them even aspire to perform the same acts that the media condemns. Too much exposure to violent scenes is not good for the development of the teenagers. Recently, there has been a huge outcry on how the media portrays violent crimes by the black Americans without discretion to the populace. It is important to note that the populace consists of diverse ages. It is ethically wrong at least according to Greer (2003) from the media to show violent crimes to the youth. It can therefore be concluded that the classical theory is indeed the most effective in explaining the media representation of violent crime by the black Americans and advancing the ways that we can deal with such perception and representation to develop more positive laws and regulation as pertains to curbing the incidences of violent crimes. Therefore, the media has been more beneficial more than detrimental to the general public through the various sensitization programs that it advocates for in totality. Crime rates by the black Americans have been effectively reduced due to the proactive nature of the media towards informing the public and the police together with other law enforcement agencies of the impending violent crimes and their consequences.

Essay --

In this day and age, many argue that the United States has an â€Å"apathy problem.† According to The Huffington Post, â€Å"America is truly exceptional in its ability not to care.† The only time we are concerned about an issue, is only if and when it personally affects us. This is also the circumstance in regards to politics. Citizens must have reliable information in order to make good, rational decisions that will help our political system run efficiently. Unfortunately, this is not always the case. According to Converse, â€Å"most Americans glance at public life innocent of ideological concepts and unguided by any broad outlook on government policy† (Kinder and Sanders, 1996, p. 167). In such a society, there is no such thing as equal representation, only popular representation, as a result of the disparities and ignorance of the people. Converse makes very valid arguments that confirm that regardless of ideological innocence, political electorates, as a wh ole, will continue to be consistent with the changing conditions of society. In the past, the â€Å"information problem† was the scarcity of information and the disconnected flow of information to the voters. Today, the problem is one of â€Å"superabundance† (Converse, 1990, p. 371). Because there is such a massive volume of information available, it is difficult to organize and rummage through it all. Corresponding to Down’s Rational Choice theory, rational voters will not make an effort to analyze such information because there are higher costs than benefits to search through and find â€Å"good† information (Converse, 1964, p. 33). Consequently, there is a huge disparity—a difference that we greatly underestimate—between the ignorant and the well-informed constituents. According to Converse, there... ...presentation fidelity â€Å"is higher for the better-educated constituents† (Converse, 1990, p. 387). This is the case because politically sophisticated entities will be more vocal and more involved in legislation. Our society is a mix of the two models, issue-public and top-down, so it only makes sense that information will be unequally distributed. Although we don't like to admit it much, we are a very indifferent society, so people do not care; they will simply delve into and further develop their expertise on topics that they are specifically interested in. However, there is no need to fret. Everyone is different and has distinct interests and skills. After all, there are nine different types of intelligences—some excel in Math while others outshine in English. Therefore, we should leave politics to the professionals and the well-informed constituents.

Adr in an Era of Globalisation: an Indian Perspective

In a country with a population in excess of a billion, and plagued by an underfunded court structure full of corrupt and ineffecient officers, we are looking at decades of stagnation, a backlog of cases in excess of 29 million, across the state-level courts, the twenty-one high courts and the supreme court. According to Global Corruption Report 2007: Corruption in Judicial Systems, Indians shelled out an estimated $600 billion as bribes to the judiciary, which is higher than the bribes paid out in any other sector in the court. This long gestation period of litigation has resulted in a large scale loss of confidence in the judiciary, with a growing number of people opting to stay away from court. Enter alternate dispute resolution. It is this plethora of people who are prime targets of an alternate dispute mechanism. The prime time solution to the snail's pace discharge of cases. The main selling point of arbitration is the speedy and cheap resolution of disputes outside of a courtroom. While arbitration is a product of a private agreement, once an arbitration award is rendered, the prevailing party can seek to have that award confirmed by the courts, and, having done so, can invoke the coercive power of the state to enforce it in the same manner as it could a court judgment. Initially received with skepticism by the courts in various countries, arbitration is now being embraced as an effective form of alternate dispute resolution. As a result of the burgeoning international trade and an explosion in the foreign direct investment numbers in the country, arbitration and other forms of alternate dispute resolution are becoming more and more indispensable. One of the major problems with foreign litigation is that foreign judgments are subject to several layers of appellate review, whereas, foreign awards are much easier to enforce in different sovereign states. Arbitration is particularly successful in fields like construction, where a certain amount of expertise is required while resolving disputes, of which there is paucity in the courts. Arbitrators are chosen from the same industry, and are generally required to resolve disputes based on fact rather than legal issues. Most companies prefer such a business approach to resolution of disputes, rather than a legal approach. Arbitration in India was first governed by the Arbitration and Conciliation Act, 1940, which was later replace by the 1996 Act. The 1996 Act was designed primarily to implement the UNCITRAL Model Law on International Commercial Arbitration and create a pro-arbitration legal regime in India. This Act was largely aimed at subduing the loopholes which allowed for excessive judicial intervention in the 1940 Act. Some of the features of judicial review The words in Section 30 of the 1940 Act read â€Å"shall not be set aside† took away the jurisdiction of the courts to set aside an award except on one or more of the grounds specified in the section. Amended in 1996, however, the section re-numbered section 34 reads â€Å"An award may be set aside only if†¦Ã¢â‚¬  Hence, the court has no jurisdiction to set aside an award on any other grounds. This amendment was brought with an intention to reduce the scope of judicial review to allow for a minimum level of court intervention. In R. S. Avtar Singh & Co. v. N. P. C. C. Ltd. , the court commented on the nature and extent of the court’s jurisdiction: It is a well settled principle of law that the award of the arbitrator who is a chosen judge of facts and of law between the parties cannot be set aside unless an error is apparent on the face of the award or it can be inferred from the award that the arbitrator has misconducted himself or the proceedings or that he has not applied his mind to the material facts. Hence, the court is not sitting in appeal on the award, nor can it re-examine the material which was adduced before the arbitrator. The court cannot examine the correctness of the award on merits nor it is obligatory for the arbitrator to give detailed reasons. Unless the court comes to the conclusion that the award is preposterous, it cannot set aside nor substitute its own decision in place of the arbitrator. In short, the arbitrator is the final judge of facts and law, and the arbitral award is not open to challenge on the ground that the arbitrator has reached a wrong conclusion or failed to appreciate the facts. Section 31 (3) of the new Act of 1996 states that an arbitral award shall state the reasons upon which it is based, unless the parties have agreed otherwise, or the award is agreed on the terms enumerated under Section 30. This was reiterated by the court in the case of Tamil Nadu Electricity Board v. Bridge Tunnel Construction Co.. The rationale behind this order of the court is to ensure that the arbitrator acts capriciously, and to give the parties assurance that the grounds for the course of action chosen by him and reasonable and just. At the same time, however, to ensure the finality of the award, reasonable of reasons given by an arbitrator cannot be challenged on merits. Why judicial review? The main purpose of arbitrator’s is to try to decide disputes correctly on the basis of the applicable law, and subsequently, explain the rationale for their decision. The need for a provision for judicial review in the field of arbitration is born out of the state’s concern to maintain the integrity of the arbitral process, and maintain a balance between party autonomy and the laws of the land. Judicial review is primarily intended to guard against arbitrariness of awards, and to ensure that the law of the land is followed within the state’s jurisdiction. No doubt judicial intervention is a requisite in the field of arbitration which lacks a certain decisional law in the matter. However, the issue to be addressed is to what extent, and an attempt is to be made to define the scope of this judicial intervention. To what extent can court’s come forward and substitute their judgment for the arbitral award? Parties who are dissatisfied with arbitration awards often call upon the courts for review. Procedurally, review is sought in an action to modify the award or set it aside; by way of defense, in a proceeding brought to enforce the arbitrator's decision; or, by way of replication, in an action where the dissatisfied party has sued on his original claim and the satisfied party has pleaded the award. One of the major problems with the 1996 Act, is that a person aggrieved by an arbitral award has to start right from the District court in order to hallenge an award. Additionally, in two recent Supreme Court decisions, Oil & Natural Gas Corporation v. SAW Pipes and SBP v. Patel Engineering, the scope of judicial review has been widened by interpreting anything contrary to â€Å"public policy† as being â€Å"patently illegal†, and since any award which contravenes Indian statutory provisions is patently illegal, it is also contrary to public policy, and hence, subject to the j udicial review of courts. Generally speaking, arbitral awards are not subject to appeal. However, in most countries, including India, there are provisions to set aside an award in extreme cases. Judicial review of foreign arbitral awards generally falls into two categories. First, the reviewing court inquires whether requirements of natural justice were observed in the arbitration proceeding and whether the arbitration agreement is valid under the applicable law. Failing so, the arbitral award will be denied recognition or enforcement on the grounds that the fundamental requirements of natural justice or legality have not been met. Subsequently, the court inquires into the merits of the award, that is, whether the arbitral body has committed an error in rendering the award. The question of judicial review, however, is a two-headed coin. On the one hand, limiting the scope of judicial review reaffirms the roots of arbitration, that is efficient and speedy resolution of disputes. Conversely, however, widening the scope of judicial review defeats the very concept of finality of an arbitral award, and hence, moving back to square one of the legal court system. Why not? The way in which the proceedings under the Act are conducted and without an exception challenged in courts has made lawyers laugh and legal philosophers weep. Experience shows and law reports bear testimony that the proceedings under the Act have become highly technical accompanied by unending prolixity at every stage providing a legal trap to the unwary. An informal forum chosen by the parties for expeditious disposal of their disputes has by the decisions of the courts been clothed with â€Å"Legalese† of unforeseen omplexity. To the critics of judicial review of arbitral proceedings, the likelihood and to an extent, inevitability of judicial review serves as a serious deterrent to individuals and companies seeking arbitration as a solution to commercial disputes. A certain school of thought views arbitration as a mere dress rehearsal for subsequent litigation, and disregards judicial review as a mere interference to the finality of the arbitral award. India is a co untry growing in leaps and bounds, with the coming of globalization. Being a country looking to attract more foreign investment, developing a fool-proof, cost-efficient and speedy legal system is vital. When a foreign company explores the prospects of investing in India, they factor in the possible legal costs, and the opportunity to settle disputes through arbitration quickly and cheaply is an attractive selling point. However, with increasing judicial intervention, and the inevitability of ending up in court, hassle-free dispute resolution is no longer a pro on their list of pro’s and con’s. Hence, the 1996 Act was passed with the objective to minimize the supervisory role of the courts in the arbitral process. The very epitome of minimal judicial intervention is contained in Section 5 of the Arbitration and Conciliation Act, 1996, which reads: â€Å"Notwithstanding anything contained in any other law for the time being in force, no judicial authority is to intervene except as provided in the Act† Section 34 of the Act imposes certain restrictions on the right of the court to set aside an arbitral award, and the limited grounds on which the award can be challenged have been enumerated. The five grounds upon which an award can be set aside as per Section 34 (2) (a) are: -Incapacity of parties -Non-existence or invalidity of arbitration agreement -Exceeding jurisdiction -Non-compliance of due process -Composition of arbitral tribunal As per Section 34 (2) (b), an arbitral award may also be set aside by the court on it’s own initiative if the subject matter of the dispute is not arbitrable or the impugned award is in conflict with the public policy of India. Public policy, however, has not been defined anywhere in the Act. Borrowing the definition of public policy from Section 23 of the Indian Contract Act, 1872: â€Å"The consideration or object of an agreement is lawful, unless – it is forbidden by law; or is of such nature that, if permitted, it would defeat the provisions of any law; or is fraudulent; or involves or implies injury to the person or property of another; or the court regards it as immoral, or opposed to public policy. † The court, over the years, has subscribed to varying conceptions of public policy, swinging between the narrow view and the broader view. In Gherulal Parakh v. Mahadeodas Maiya, the court favoured the narrower view, and commented that: â€Å"†¦though the heads are not closed and though theoretically it may be permissible to evolve a new head under exceptional circumstances of a changing world, it is admissible in the interest of stability of society not to make any attempt to discover new heads in these days. † With respect to public policy in the field of arbitration, the court held in Renusagar Power Co. Ltd. v. General Electric Co. , that in order to attract the bar of public policy the enforcement of the award must invoke something more than the violation of the law of India. It was held that the enforcement of a foreign award would be refused on the ground that it is contrary to public policy if such enforcement would be contrary to: -Fundamental policy of Indian law -The interest of India -Justice or morality The court in recent times, however, has subscribed to the broader view of public policy, choosing to widen the scope of judicial review. A landmark judgment in this respect is Oil & Natural Gas Corporation Ltd. v. SAW Pipes Ltd.. The crux of the case was that the arbitral tribunal had failed to take into account Section 73 and 74 of the Indian Contract Act, 1872. The major issue, however, that it dealt with was whether the Court would have jurisdiction under Section 34 of the 1996 Act to set aside an award passed by the Arbitral Tribunal which is patently illegal or in contravention of the provisions of the Act, or any substantive law governing the parties, or is against the terms of the contract. The judgment of the court in this case, not only negated the purpose of the 1996 Act, but also widened the scope of judicial review beyond the realms provided for in the 1940 Act as well. It was held that an award is opposed to â€Å"public policy† under the same heads laid down in Renusagar Power, but also if it is: -Patently illegal -So unfair and unreasonable that it shocks the conscience of the court Another important judgment of the Supreme Court in 2005 was SBP & Co. v. Patel Engineering, which sanctioned further intervention in the judicial process. The case dealt with the appointment of an arbitrator by the Chief Justice, and the contention was that the Chief Justice could adjudicate on contentious preliminary issues such as the existence of a valid arbitration agreement. The court agreed, while holding that the Chief Justice’s findings would be final and binding on the arbitration tribunal. This judgment makes a mockery of the principle of Kompetenz Kompetenz, which is the power of an arbitral tribunal to determine its own jurisdiction, enshrined in Section 16 of the 1996 Act. This opens up a Pandora’s box of opportunity for parties to sabotage the appointment process of arbitrators and make spurious arguments simply to delay the arbitration proceedings. Looking Ahead It is easy to forget the purpose of arbitration and get carried away with the nuances of the law. Therefore, in an attempt to move forward, it is important to incorporate the very aspect of finality and amicable resolution in the contract itself. Of course the most apparent solution at the face of it is to close all doors to review of the award by incorporating a clause for the same in the contract. However, this can only be done at the risk of receiving an award not in line with the principles of natural justice. On the legislature’s part, the Arbitration and Conciliation (Amendment) Bill, 2003, currently pending before the Parliament, proposes to introduce a new section 34A, which would allow an award to be set aside â€Å"where there is an error apparent on the face of the arbitration award giving rise to a substantial question of law†. This narrows the scope for review laid down by the SAW Pipes ruling, but it still affords losing parties an opportunity to approach courts in an attempt to second – guess arbitral tribunals, very similar to the position during the applicability of the 1940 Act. An interesting avenue to be explored in the future, particularly in the case of contracts involving large sums of money, is a system of contemporary and concurrent dispute resolution, involving the establishment of Dispute Review Boards (DRBs). This system has been adopted by the National Highway Authority of India (NHAI), Maharashtra Sewerage Board and Delhi Metro in recent times. A Dispute Review Board basically consists of three experienced, respected and impartial reviewers. It is constituted before the commencement of the contract, and regular inspections are carried out to ensure smooth functioning of the contract and ensure good working conditions. This serves to familiarize the reviewers with the job process and the basic environment as well, so that in case a dispute arises, a well-informed decision can be made. In such a case, a hearing is convened where the reviewer’s hear arguments of both sides and after deliberation submit a non-binding recommendation to the contractors.

Chemistry Lab Report on standardization of acid and bases Essay

Purpose: To prepare standardize solution of sodium hydroxide and to determine the concentration of unknown sulfuric acid solution. Data and Calculations: This experiment is divided into two parts (Part A and Part B). In the first part of experiment, the standardize solution of sodium hydroxide is prepared by titrating it with base Potassium hydrogen phthalate (KHP). The indicator Phenolphthalein is used to determine that whether titration is complete or not. PART A: Standardization of a Sodium Hydroxide solution NaOH Sample Code = O Trial 1 Mass of KHP transferred = 0.42 g Volume of Distilled water = 25 mL Volume of NaOH used = 22.50 mL Molar mass of KHP = 204.22 g/mol No. of moles of KHP = Mass of KHP used / Molar mass = 0.42 g / 204.22 g/mol = 0.0021 moles Concentration of NaOH = No. of moles / Volume = [0.0021 mol / {(22.50 + 25) / 1000} L] * 100 = 4.4 M Trial 2 Mass of KHP transferred = 0.4139 g Volume of Distilled water = 25 mL Volume of NaOH used = 22.80 mL Molar mass of KHP = 204.22 g/mol No. of moles of KHP = Mass of KHP used / Molar mass = 0.4139 g / 204.22 g/mol = 0.0020267 moles Concentration of NaOH = No. of moles / Volume = [0.0020267 mol / {(22.80 + 25) / 1000} L] * 100 = 4.24 M Trial 3 Mass of KHP transferred = 0.4239 g Volume of Distilled water = 25 mL Volume of NaOH used = 23.10 mL Molar mass of KHP = 204.22 g/mol No. of moles of KHP = Mass of KHP used / Molar mass = 0.4239 g / 204.22 g/mol = 0.0020757 moles Concentratio n of NaOH = No. of moles / Volume = [0.0020757 mol / {(23.10 + 25) / 1000} L] * 100 = 4.32 M Trial 4 Mass of KHP transferred = 0.4311 g Volume of Distilled water = 25 mL Volume of NaOH used = 22.60 mL Molar mass of KHP = 204.22 g/mol No. of moles of KHP = Mass of KHP used / Molar mass = 0.4311 g / 204.22 g/mol = 0.0021109 moles Concentration of NaOH = No. of moles / Volume = [0.0021109 mol / {(22.60 + 25) / 1000} L] * 100 = 4.43 M Table: Trail 1 Mass weighing bottle + KHP (g) Mass empty weighing bottle (g) Mass of KHP transferred (g) Initial volume of burette, Vi (mL) Final Volume of burette, Vf(mL) Volume of NaOH used (mL) Trial 2 Trial 3 Trial 4 11.561 11.6217 11.6113 11.6329 11.1461 11.2078 11.1874 11.2018 0.4200 0.4139 0.4239 0.4311 4.30 6.30 10.1 33.20 26.80 29.10 33.20 55.80 22.50 22.80 23.10 22.60 Concentration of NaOH (moles/L) 4.4 4.24 4.32 Average concentration of NaOH = [4.4 M + 4.24 M + 4.32 M + 4.43 M] / 4 = 4.35 M 1. % Difference between Trial 1 and Trail 2 = [4.24 M / 4.4 M] * 100 % = 96.3 % Difference = (100 – 96.3) % = 3.7 % 2. % Difference between Trial 2 and Trail 3 = [4.24 M / 4.32 M] * 100 % = 98.1 % Difference = (100 – 98.1) % = 1.9 % 3. % Difference between Trial 3 and Trail 4 = [4.32 M / 4.43 M] * 100 % = 97.5 % Difference = (100 – 97.5) % = 2.5 % 4.43 Observations: KHP is white color crystals and has definite shape. NaOH is clear and transparent solution with no color. In the first trial, after adding 90 drops of NaOH solution there was repeatedly appearance and disappearance of light pink color. When the whole solution of KHP and water get titrated then, the color of solution becomes light pink and it stays permanently. The same color changes happen with the next three trials. Concentration of NaOH was almost similar for every trials. PART B: Concentration of Sulfuric Acid solution H2SO4 Sample Code = 34 Trial 1: Volume diluted acid = 25 mL Volume of NaOH used = 14.39 mL H2SO4 (aq) + 2NaOH (aq) 2H2O (l) + 2Na2SO4 (aq) Average concentration of NaOH = 4.35 M No. of moles of NaOH = (Average concentration of NaOH) * (Volume of NaOH used) = 4.35 M * (14.39 / 1000) L = 0.0626 moles No. of moles of H2SO4 = 0.0626 mol / 2 = 0.0313 moles Concentration of H2SO4 = No. of moles / (volume of diluted acid / 1000) = 0.0313 mol / (25 / 1000) L = 1.2 M Trial 2: Volume diluted acid = 25 mL Volume of NaOH used = 13.51 mL H2SO4 (aq) + 2NaOH (aq) 2H2O (l) + 2Na2SO4 (aq) Average concentration of NaOH = 4.35 M No. of moles of NaOH = (Average concentration of NaOH) * (Volume of NaOH used) = 4.35 M * (13.51 / 1000) L = 0.0588 moles No. of moles of H2SO4 = 0.0588 mol / 2 = 0.0294 moles Concentration of H2SO4 = No. of moles / (volume of diluted acid / 1000) = 0.0294 mol / (25 / 1000) L = 1.2 M Trial 3: Volume diluted acid = 25 mL Volume of NaOH used = 14.10 mL H2SO4 (aq) + 2NaOH (aq) 2H2O (l) + 2Na2SO4 (aq) Av erage concentration of NaOH = 4.35 M No. of moles of NaOH = (Average concentration of NaOH) * (Volume of NaOH used) = 4.35 M * (14.10 / 1000) L = 0.0613 moles No. of moles of H2SO4 = 0.0613 mol / 2 = 0.0307 moles Concentration of H2SO4 = No. of moles / (volume of diluted acid / 1000) = 0.0307 mol / (25 / 1000) L = 1.2 M Trial 4: Volume diluted acid = 25 mL Volume of NaOH used = 14.20 mL H2SO4 (aq) + 2NaOH (aq) 2H2O (l) + 2Na2SO4 (aq) Average concentration of NaOH = 4.35 M No. of moles of NaOH = (Average concentration of NaOH) * (Volume of NaOH used) = 4.35 M * (14.20 / 1000) L = 0.0618 moles No. of moles of H2SO4 = 0.0618 mol / 2 = 0.0309 moles Concentration of H2SO4 = No. of moles /  (volume of diluted acid / 1000) = 0.0309 mol / (25 / 1000) L = 1.2 M % Difference between Trail 1 and Trail 2 = [1.2 M / 1.2 M] * 100 % = 100 % Difference = (100 – 100) % =0% % Difference between Trail 1 and Trail 2 = [1.2 M / 1.2 M] * 100 % = 100 % Difference = (100 – 100) % =0% % Diff erence between Trail 1 and Trail 2 = [1.2 M / 1.2 M] * 100 % = 100 % Difference = (100 – 100) % =0% % Difference between Trail 1 and Trail 2 = [1.2 M / 1.2 M] * 100 % = 100 % Difference = (100 – 100) % =0% Table 2: Trail 1 Volume diluted acid titrated (mL) Initial Volume of burette, Vi (mL) Final Volume of burette, Vf (mL) Volume NaOH used (mL) Concentration Of Sulfuric Acid Trail 2 Trial 3 Trial 4 25 25 25 25 2.41 17.20 8.50 22.60 16.94 30.71 22.60 36.80 14.39 13.51 14.10 14.20 1.2 M 1.2 M 1.2 M 1.2 M Observations: The H2SO4 is colorless and transparent liquid. The NaOH solution is colorless, odorless and transparent liquid. While doing the first trail, there were continuous appearance and disappearance of light pink color. After adding 10 mL of NaOH solution the pink color starts appearing. At certain volume the light pink color appeared, indicating that titration is done. The indictor phenolphthalein has no color and there was no specific odor of reagent. Discussion: Average concentration of NaOH solution was 4.35 M. There are many sources of error in this experiment as we got some percentage differences in the two different trials. For the Trial 1 and Trial 2, the percentage difference is 3.7 % which is significant difference to be noted. This percentage difference could occur due to many reasons such as not measuring the KHP properly as we got 0.42 g for first trial and 0.4139 g for second trial of KHP for performing titration but it is more than required value as per literature value is concerned (0.40 g). The almost same percentagedifference occurs for next two trials (1.9 % and 2.5 %). The KHP is always 99.9 % pure, so the titration should give perfect results (Lab Manual). The other possible errors was due to the disturbance on the shelf by other students where analytical balance is placed in balance room, as it cause variability in the values in weight of KHP. In Part B of experiment, the average concentration of sulfuric was found to be 1.2 M and there was 100 % titration of both reagent (NaOH and H2SO4). This 100 % results comes due to significant figures, if significant figures would not be concerned then there would be error of 1.0 % to 2.0 % in every two trials. There was identical difference of volume of NaOH used to titrate the acid for each  trial due to some possible errors. The possible errors in this Part of experiment were same as for Part A, as the process is followed in the same way. The most significant error could occur by not shaking the flask properly while adding sodium hydroxide solution and not recognizing the pink color on the instant it appears and adding the NaOH solution vigorously into the sulfuric acid. Questions: The 10 mL volumetric pipette is rinse 2 or 5 times to make sure there is no bubble inside because air bubble can cause error in the measurement of concentration because the actual volume of unknown will be less. The accuracy and precision for both sets of experiment was almost same as there were percentage difference of concentrations lies only in 2 % to 4 %. The endpoints of titration for each set of trails in both cases (Part A and Part B) were almost same but there is little difference in volume of NaOH used which cause errors in accuracy and precision of experiment. Using the analytical balance is really careful job as it is most accurate weighing machine with accuracy of 0.0004 g (Lab Manual) and we need to be prà ©cised using the balance but some few disturbance can cause big error such as disturbance other students on the shelf it is placed on and not reading the balance properly and taking measurements fastly. Using Volumetric glassware is other method to be more accurate in experiment but there are some possible random error while reading the values such as not reading the lower meniscus of liquid cause error and not removing the air bubble from the burette and using the beaker in place graduated cylinder in case of volume as graduated cylinder is more accurate as compared to beaker (0.02 g) (Lab Manual). Sources of Experimental Error include: The Analytical balance could give wrong reading because of the disturbance due to other students on the shelf it is placed on. Also, taking the reading rapidly and not considering the reading when balance display gets steady. The possible error can occur using wrong glassware like using beaker instead of graduated cylinder. The error could occur while taking reading through graduated cylinder and not considering the lower meniscus of liquid. The air bubble in burette can cause error in the true value of NaOH used. Few drops of liquid remain in burette and volumetric pipette which causes the error. Not shaking the flask properly while adding the NaOH solution. Adding the NaOH solution vigorously into the flask. Not recognizing the pink color instantly as it appears.  Adding the more drops of indicator as needed (2 or 3 drops). The biggest error occur due to leaking of NaOH solution form burette, we lost 4 drops during every one trial and it cause the significant error in reading the volume of NaOH used. There is water left after washing the glass wares which can cause the error. This lab could be improved by improving the method of drying the graduated cylinder and beaker before filling it with the NaOH solution. The glassware could be dried by small amount of acetone. Any acetone could be removed by evaporation. Finally, the experimenter should remove the clinging droplets to the neck of burette and volumetric pipette by using Kim Wipe. Conclusion: After careful consideration of all the results and all the possible concentration, it is concluded that the average concentration of NaOH (sample code O) was 4.35 M and average concentration of H2SO4 (sample code 34) was 1.2 M.

Biography of Kate Chase Sprague, Political Daughter

Biography of Kate Chase Sprague, Political Daughter Kate Chase Sprague (born Catherine Jane Chase; August 13, 1840–July 31, 1899) was a society hostess during the Civil War years in Washington, D.C. She was celebrated for her beauty, intellect, and political savvy. Her father was Secretary of the Treasury Salmon P. Chase, part of President Abraham Lincolns Team of Rivals, and later served as secretary of state and chief justice of the United States Supreme Court. Kate helped promote her fathers political ambitions before she became embroiled in a scandalous marriage and divorce. Fast Facts: Kate Chase Sprague Known For:  Socialite, daughter of a prominent politician, embroiled in a scandalous marriage and divorceAlso Known As:  Kate Chase, Katherine ChaseBorn:  August 13, 1840 in Cincinnati, OhioParents: Salmon Portland Chase and Eliza Ann Smith ChaseDied:  July 31, 1899 in Washington, D.C.Education: Miss Haines School, Lewis Heyl’s SeminarySpouse: William SpragueChildren: William, Ethel, Portia, Catherine (or Kitty)Notable Quote: â€Å"Mrs. Lincoln was piqued that I did not remain at Columbus to see her, and I have always felt that this was the chief reason why she did not like me at Washington.† Early Life Kate Chase was born in Cincinnati, Ohio, on August 13, 1840.  Her father was Salmon P. Chase and her mother was Eliza Ann Smith, his second wife.   In 1845, Kate’s mother died, and her father remarried the next year.  He had another daughter, Nettie, with his third wife Sarah Ludlow. Kate was jealous of her stepmother and so her father sent her to the fashionable and rigorous Miss Haines School in New York City in 1846.  Kate graduated in 1856 and returned to Columbus. Ohio’s First Lady In 1849 while Kate was at school, her father was elected to the U.S. Senate as a representative of the Free Soil Party.  His third wife died in 1852, and in 1856 he was elected as Ohio’s governor.  Kate, at age 16, had recently returned from boarding school and became close to her father, serving as his official hostess at the governor’s mansion.  Kate also began serving as her father’s secretary and advisor and was able to meet many prominent political figures. In 1859, Kate failed to attend a reception for the wife of Illinois Senator Abraham Lincoln. Kate said of this occasion, â€Å"Mrs. Lincoln was piqued that I did not remain at Columbus to see her, and I have always felt that this was the chief reason why she did not like me at Washington.† Salmon Chase had a more momentous rivalry with Senator Lincoln, competing with him for the Republican nomination for president in 1860. Kate Chase accompanied her father to Chicago for the national Republican convention, where Lincoln prevailed. Kate Chase in Washington Although Salmon Chase had failed in his attempt to become president, Lincoln appointed him secretary of the treasury. Kate accompanied her father to Washington, D.C., where they moved into a rented mansion.  Kate held salons at the home from 1861 to 1863 and continued to serve as her father’s hostess and advisor. With her intellect, beauty, and expensive fashions, she was a central figure in Washington’s social scene. She was in direct competition with Mary Todd Lincoln. Mrs. Lincoln, as the White House hostess, had the position that Kate Chase coveted. The rivalry between the two was publicly noted. Kate Chase visited battle camps near Washington, D.C. and publicly criticized the president’s policies on the war. Suitors Kate had many suitors.  In 1862, she met newly elected Senator William Sprague from Rhode Island.  Sprague had inherited his family business in textile and locomotive manufacturing and was very wealthy. He had already been something of a hero in the early Civil War. He was elected Rhode Island’s governor in 1860 and in 1861, during his term in office, he enlisted in the Union Army. At the first Battle of Bull Run, he acquitted himself well. Wedding Kate Chase and William Sprague became engaged, though the relationship was stormy from the beginning. Sprague broke off the engagement briefly when he discovered Kate had had a romance with a married man. They reconciled and were married in an extravagant wedding at the Chase home on November 12, 1863. The press covered the ceremony.  A reported 500 to 600 guests attended and a crowd  also assembled outside the home. Sprague’s gift to his wife was a $50,000 tiara. President Lincoln and most of the cabinet attended. The press noted that the president arrived alone: Mary Todd Lincoln had snubbed Kate. Political Maneuvering Kate Chase Sprague and her new husband moved into her father’s mansion, and Kate continued to be the toast of the town and preside at social functions.  Salmon Chase bought land in suburban Washington, at Edgewood, and began to build his own mansion there. Kate helped advise and support her father’s 1864 attempt to be nominated over incumbent Abraham Lincoln by the Republican convention. William Sprague’s money helped support the campaign. Salmon Chase’s second attempt to become president also failed. Lincoln accepted his resignation as secretary of the treasury.  When Roger Taney died, Lincoln appointed Salmon P. Chase as chief justice of the Supreme Court. Early Marriage Troubles Kate and William Sprague’s first child and only son William was born in 1865.  By 1866, rumors that the marriage might end were quite public. William drank heavily, had open affairs, and was reported to be physically and verbally abusive to his wife. Kate, for her part, was extravagant with the family’s money. She spent lavishly on her father’s political career as well as fashion- even as she criticized Mary Todd Lincoln for her purported frivolous spending. 1868 Presidential Politics In 1868, Salmon P. Chase presided at the impeachment trial of President Andrew Johnson.  Chase already had his eye on the presidential nomination for later that year and Kate recognized that if Johnson was convicted, his successor would likely run as an incumbent, reducing Salmon Chase’s chances of nomination and election. Kate’s husband was among the senators voting on the impeachment. Like many Republicans, he voted for conviction, likely increasing tension between William and Kate.  Johnson’s conviction failed by one vote. Switching Parties Ulysses S. Grant won the Republican nomination for the presidency, and Salmon Chase decided to switch parties and run as a Democrat.  Kate accompanied her father to New York City, where the Tammany Hall convention did not select Salmon Chase. She blamed New York governor Samuel J. Tilden for engineering her father’s defeat. Historians deem it more likely that it was his support for voting rights for black men that led to Chases defeat.  Salmon Chase retired to his Edgewood mansion. Scandals and a Deteriorating Marriage Salmon Chase had become politically entangled with financier Jay Cooke, beginning with some special favors in 1862.  When criticized for accepting gifts as a public servant, Chase stated  that  a carriage from Cooke was actually a gift to his daughter. That same year, the Spragues built a massive mansion in Narragansett Pier, Rhode Island. Kate took many trips to Europe and New York City, spending heavily on furnishing the mansion. Her father wrote to her to caution her that she was being too extravagant with her husband’s money.  In 1869, Kate gave birth to her second child, this time a daughter named Ethel, though rumors of their deteriorating marriage increased. In 1872, Salmon Chase made yet another try for the presidential nomination, this time as a Republican.  He failed again and died the next year. More Scandals William Sprague’s finances suffered huge losses in the depression of 1873. After her father’s death, Kate began spending most of her time at her late fathers Edgewood mansion.  She also began an affair at some point with New York Senator Roscoe Conkling, with rumors spreading that her last two daughters were not her husband’s. After her father’s death, the affair became more and more public. With whispers of scandal, the men of Washington still attended many parties at Edgewood hosted by Kate Sprague. Their wives attended only if they had to. After William Sprague left the Senate in 1875, the attendance by the wives virtually ceased. In 1876, Kates paramour Senator Conkling was a key figure in the Senate’s deciding the presidential election in favor of Rutherford B. Hayes over Kate’s old enemy, Samuel J. Tilden. Tilden had won the popular vote. The Marriage Breaks Kate and William Sprague lived mostly separately, but in August of 1879, Kate and her daughters were at home in Rhode Island when William Sprague left on a business trip.  According to the sensational stories in the newspapers later, Sprague returned unexpectedly from his trip and found Kate with Conkling. Newspapers wrote that Sprague pursued Conkling into town with a shotgun, then imprisoned Kate and threatened to throw her out a second-floor window.  Kate and her daughters escaped with the help of servants and they returned to Edgewood. Divorce The next year, 1880, Kate filed for divorce. Pursuing a divorce was difficult for a woman under the laws of the time. She asked for custody of the four children and for the right to resume her maiden name, also unusual for the time. The case dragged on until 1882, when she won custody of their three daughters, with their son to remain with his father. She also won the right to be called Mrs. Kate Chase rather than using the name Sprague. Declining Fortune Kate took her three daughters to live in Europe in 1882 after the divorce was final. They lived there until 1886 when their money ran out, and she returned with her daughters to Edgewood. Chase began selling off the furniture and silver and mortgaging the home.  She was reduced to selling milk and eggs door to door to sustain herself.  In 1890, her son committed suicide at age 25, which caused Kate to become more reclusive. Her daughters Ethel and Portia moved out, Portia to Rhode Island and Ethel, who married, to Brooklyn, New York.  Kitty was mentally disabled and lived with her mother. In 1896, a group of admirers of Kate’s father paid the mortgage on Edgewood, allowing her some financial security.  Henry Villard, married to the daughter of abolitionist William Garrison, headed that effort. Death In 1899 after ignoring a serious illness for some time, Kate sought medical help for liver and kidney disease.  She died on July 31, 1899, of Bright’s disease, with her three daughters at her side. A U.S. government car brought her back to Columbus, Ohio, where she was buried next to her father.  Obituaries called her by her married name, Kate Chase Sprague. Legacy Despite her unhappy marriage and the devastation wrought on her reputation and clout by the scandal of her infidelity, Kate Chase Sprague is remembered as a remarkably brilliant and accomplished woman. As her fathers de facto campaign manager and as a central Washington society hostess, she wielded political power during the greatest crisis in United States history, the Civil War and its aftermath. Sources Goodwin, Doris Kearns. Team of Rivals: The Political Genius of Abraham Lincoln. Simon and Schuster, 2005.  Ishbel Ross. Proud Kate, Portrait of an Ambitious Woman. Harper, 1953.â€Å"Notable Visitors: Kate Chase Sprague (1840-1899).†Ã‚  Mr. Lincolns White House, www.mrlincolnswhitehouse.org/residents-visitors/notable-visitors/notable-visitors-kate-chase-sprague-1840-1899/.Oller, John. American Queen: The Rise and Fall of Kate Chase Sprague, Civil War â€Å"Belle of the North and Gilded Age Woman of Scandal. Da Capo Press, 2014