New Opportunities in the Online Marketplace - 1900 Words

There are always new opportunities to build our rapidly changing market economy that leaves no one behind. Markets use these opportunities to create an atmosphere of ambition between individuals to exceed one another and in turn generate a more dynamic, self sufficient economy. However, leading more toward a market economy there are greater responsibilities held on many retailer’s shoulders. The market place has grown so much that it is not just actual â€Å"professionals† exchanging/selling goods and services to consumers, but also people that are not necessarily a professional in a business through online markets. When discussing about online markets, many sellers use the advantage of the internet to increase revenues. We use online markets mainly to benefit both the buyer and seller in many ways. One specific benefit that they both find very favorable to them is the fact that there is no sales tax involved in the transactions made in certain online market systems. A mazon, E-bay, and other retailer websites that operate under this certain online market system do not collect sales taxes from customers. The only reason for the exemption of collecting and remitting of sales tax to the state in which they execute a sale in, is that they do not have a physical presence â€Å"nexus† in states where they sell their product to their online customers. This starts to become an issue to traditional businesses that have to collect and remit sales taxes to the state and also the state itself.Show MoreRelatedEbay Is The Leading Global Brand For Online Auctions1182 Words   |  5 Pagesleading global brand for online auctions. The company is a giant marketplace used by more than 100 million people to buy and sell all manner of things to each other. The brand has grown tremendously over the decade or so since its conception. 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Vestigial Organs Common Descent by Charles Darwing

â€Å"Vestigial Organ† is a term used to describe organs or functions that due to the course of evolution no longer have a use. The idea of useless organs had been around long before Charles Darwin, but his idea for why they were there was the one that stuck. In his book â€Å"The Descent of Man† Darwin named a few organs that were considered absolutely useless or had very little service such as wisdom teeth, the appendix, the spleen, and the hind leg bones in whales. While functions of some of these parts such as the appendix and spleen have been discovered, Evolutionists still believe that vestigial are great evidence for the evolution. In complete contrast, Creationists know that they are evidence for a Creator. They believe that the organs are†¦show more content†¦So why then has it popped back up? Evolutionists are unsure, but they do know that the mid tarsal break strongly points toward ancestry from apes. Creationists on the other hand who do not believe that humans descended from apes, must come up with an explanation for these useless functions and parts. Their simple explanation for useless organs and functions? They aren’t useless. A random, meaningless organ in the body does not point toward a divine Creator, why would God put useless parts into his creation. He wouldn’t. Genesis 1: 31 â€Å"God saw all that he had made, and it was very good. And there was evening, and there was morning — the sixth day† If something is very good it isn’t made with nonfunctional parts. That would mean that all organs must have a function that is noteworthy. If there isn’t a function that would only mean that we haven’t figured out what it is yet. Interestingly, Creationists view wisdom teeth in a similar way Evolutionists do. In countries that aren’t as developed, technologically, people there do not eat as much processed food. As a result their jaws are stronger from chewing harder food. Their stronger jaws are able to accamodate the third molars. Also due to their tougher diet, their teeth wear down, so more teeth helps. God fully equipped us for eating, with strong jaws and teeth. Our mouths can take the wisdom teeth, it would seem we are taking care of our teeth too well. Also since the fall of Eden, disease has plagued life on

Strength-Based Nursing and Healthcare for Emma Gee - myassignmenthelp

Question: Discuss about theStrength-Based Nursing and Healthcare for Emma Gee. Answer: This discussion looks at the life of Emma Gee and the relevance of implementing a Strengths-Based Nursing (SBN) plan in her healthcare as she struggled to recover from a stroke. Emma Gee was an energetic young therapist whose life was turned around after suffering a stroke. Due to the presence of an arteriovenous malformation (AVM), doctors scheduled a brain surgery for Emma. It was during the high-risk surgery procedure that Emma developed complications and suffered a stroke. Doctors immediately put Emma into an induced coma after the surgery. She later woke up unable to move or even speak. Through nursing and healthcare efforts from Dalcross Hospital, Royal Talbot Rehabilitation Centre and her family, Emma was able to recover and she is now a renowned motivational speaker and occupational theapist.The discussion looks at Emmas healthcare experiences after she regained consciousness and during her rehabilitation. Based on her experiences, the discusion suggests how implementing a St renths-Based Nursing and Healthcare approach could have made a difference in Emmas recovery. Overview of Strengths-Based Principles Strength-based nursing and health care (SBNC) is an approach that aims to create conditions whereby patients experience healing in their lifespan through the promotion of health and optimisation of their wellbeing and functioning. SBNC is about discovering, uncovering, understanding, and releasing social, interpersonal, intrapersonal, and biological strengths to meet healthcare and personal goals while dealing with the challenges. SBN is based on the guiding principles of collaborative partnership, relational care, empowerment and movement, person and family-centered care, and holistic care (Gottlieb, Gottlieb and Shamian, 2012). These principles provide hope, self-efficacy, and empowerment. It means that there should be a collaboration between the healthcare team and the patient while empowering him/her and the family to find meaning and attain their objectives. It also requires the health care team to understand the individual in whole by facilitating personalized care, holistic ca re, and whole-person nursing care.The principles aim to ensure the affected individual is responsible and takes charge of his or her healing and recovery process. Gottlieb (2012) outlined eight values that underly SBN. These include self-determination, person and environment are integral, subject reality and created meaning, holism, and embodiment, uniqueness, health and healing, collaborative partnership, learning, timing, and readiness. According to Gottlieb (2012), practicing a SBN model of health care promotes the quality of life, health behaviors, and brings hope to stroke survivors such as Emma Gee. It is especially important in Australias healthcare system whereby there are over 440,000 Australians directly affected by the effects of stroke (Rosamond et al., 2008). The National Stroke Foundation which is among the leading stroke support group in Australia approximates that over $44 million is needed to tackle the effects of stroke over a four year period. Implementation of Strengths-Based Nursing in Emmas case This discussion looks at a case study on Emma Gee and investigates on the most appropriate ways in which a SBNC approach could have been implemented to assist Emma during her journey after suffering a life-changing stroke. After suffering a stroke at such a young age, Emma faced a lot of challenges in her new way of life. Being an active girl as evidenced by her various outdoor activities such as running and netball, Emma was devastated after the stroke and she had to accept her new reality. While in the induced coma, after regaining consciousness, during her rehabilitation, and in her integration back to the community, Emma had various health care needs. Implementing a SBN approach during her recovery journey could have greatly impacted the healthcare outcome and facilitated her wholesome recovery. Most importantly, a SBNC approach would have empowered and ensured collaboration between Emma, her family, and her healtcare providers. There are various challenges Emma encountered in he r journey that could have been better addressed using a SBN model. These challenges range from dysphagia, balance and mobility complications, loneliness, environmental irritation, dysarthria, double incontinence, societal issues, to dependency. Furthermore, it is important to empower patients and ensure that they participate in their well being by involving them in decisin making activities. Relationships In Nursing Practice SBNC provides a guidance framework for nurses and other healthcare professionals. It facilitates the expansion of a nurses imaginary horizon and the providence of innovative solutions that solve long-term health care problems. While delivering medical services, healthcare professionals should have put themselves in Emmas shoes. It would have ensured they understand what she went through physically, mentally, emotionally, and even spiritually (Kobau et al., 2011). According to Lietz (2007), SBNC broadens healthcare focus to include the well being, quality of life, healing and health of the whole person. It encourages a shift from analyzing the outcomes of health care as assessed by health practitioners to focusing on client-based outcomes. It is all about patients and the health care system combining effort to get the most of what is both meaningful and important to them.Such an approach would ensure the suffering experienced by stroke victims is minimised. While in hospital, Emma exp erienced double incontinence meaning she had lost control of her bowels and therefore needed to use a catheter. The nurses showed little or no empathy for her as evidenced by how they treated and acted towards her care. Emma even often felt embarrassed by the situation. Involving her parents or sister in cleaning up Emma would have made her feel more comfortable. Collaboration between her family and the nurses would have ensured Emma recovered from this stage of her journey in a personalized manner. Generally, nurses should have taken a personalized approach aimed at empowering Emma while collaborating with her family. Transition Points When formulating a SBN care plan, it is crucial to involve the patients, their families, and carers to facilitate procedures, clear health care expectations, investigations, and discharge of the patients in a collaborative manner. This helps in empowering the patient and helping him/her take charge of their recovery. A strength-based nursing care plan must consider verbal communication with the patient and family, previous documentation on the patient, clinical handover, and an assessment of the patient. Regaining Consciousness This discussion presents a SBN care plan following Emma regaining consciousness and focuses on collaboration between Emma, her family and other healthcare professionals involved in Emmas case. For clinical documentation of Emmas case, the study will adopt a multidisciplinary team approach and a SOAP framework to provide collaborated health care and communicate information on Emmas progress to everyone invested in her recovery (Donohoe, 2015).After Emma regained consciousness, she faced various deficits such as trouble swallowing, vertigo, double incontinence, diplopia, left-side paralysis, right-side facial paralysis, mobility and balance issues among others. To facilitate her recovery, it is crucial to implement a SBN care plan that propagates collaboration between Emma, her family and healthcare professionals. The first step in developing the SBN care plan is to assess existing medical and personal information on Emma. It includes her emotional, social, family, mental, and physical history. To help her successfully transition and recover after the coma, it is important to determine and understand the factors surrounding her current condition. The next step of the care plan would be to observe the real-time progress of Emma. It includes Emmas current condition such as her inability to swallow food. Through collaboration between Emma, her family members and the multidisciplinary team consisting of nurses under the guidance of a speech therapist, Emmas situation can be analyzed, and appropriate interventions applied. This care plan would encompass educating and involving Emmas family in assisting her with her swallowing complications. The outcome of the procedure would then be analyzed, and appropriate changes implemented based on Emmas response to the intervention. Aside from educating and sensitizing them on the importance of collaborative healthcare approach, Emmas family would constantly be updated on her progress and response. The care plan would further en sure that Emmas family are consulted before, and present during any landmark decisions and progress on Emmas recovery journey in the hospital. Rehabilitation SBN practices during a patients rehabilitation should be geared towards helping the patient bounce back from their unfortunate scenario. A SBN care plan for Emma while at the Royal Talbot Rehabilitation Centre should have been focussed on empowerng Emma to take active part in her rehabilitation process. It was the responsibility of the nurses and Emmas parents to work together with Emma and give her the motivation she needed. Under a SBN care plan, Emmas nurses such as Fran, should have used a person-centered approach while rehabilitating Emma. A SBN care plan would include a multidisciplinary team comprised of nurses and specialists to help in the therapy process of Emma. This team would focus on making Emma feel valued in order to motivate and empower her to perform. The care plan would follow a carefully formulated therapy scheduleas determined by the input of Emma, her parents and the therapists at Talbot. It is also important to ensure patients are rehabilitated in a condusive e nvironment. Unlike the brisk and careless attitude experienced at Talbot, a warm and nurturing approach to give Emma a sense of belonging would have been better suited to Emmas situation. Such an environment would foster a feeling of comfort synonymous with having a family. Emma often felt dependent and powerless as a result off the care plan practiced at Talbot. This only made Emma feel vulnerable instead of empowered. Emmas family and friends clearly supported her as evidenced in their unannouced visits and even the RUN to GEE fundraiser to support Talbot. This kind of support compliments a SBN care plan by fuelling the recovery of a patient. Reflection of Emmas Experience Although Emma had caring parents and an identical twin sister who understood her, she felt lonely and sad while in admitted in the hospital, during rehabilitation and even after being integrated back into the community. The best approach would have been to sensitize her family and friends on the importance of communal support in facilitating the recovery process of a stroke victim (Wells et al., 2014). Emma needed to be emotionally motivated and supported to ensure her quick recovery, health, and quality of life. It is important to have a sense of belonging and a hand to help you through such a difficult time (Havens, Wood and Leeman, 2006). It was of grave importance for her family and friends to be actively involved in her recovery by visiting her a frequent as possible and showing her that they cared and supported her along her journey. Knowing she had the support of her family and medical staff would have fostered resilience in Emma throughout her recovery journey. Before the unfortunate incident, Emma had been fond of food and cuisines as seen in her association of family time and visitors with food and other gifts.It however, took a negative turn since she started showing symptoms that were later diagnosed as an Arteriovenous malformation (AVM). The situation only worsened when she suffered a stroke and upon gaining consciousness, experienced dysphagia. Due to the difficulties faced by Emma while trying to swallow food, tubes were shoved down her throat to help her. During her recovery process in the hospital, Emmas speech therapist taught her feeders to encourage the food downwards by stroking her neck although Emma found the idea quite unpleasant. By facilitating a SBN approach focused on empowering Emma while ensuring family involvement, it would have been more prudent to involve Emmas parents or sister in this particular process. By providing her with the understanding yet familiar touch of her family, Emma would have been more comfortabl e. This familiarity coupled with her evident determination to recover and return to normal eating habits would have benefitted both Emmas well being and functioning. Emma was greatly disturbed by sound and visual irritations. Her communication and mobility challenges made it hard for her to do anything about these irritations. It is important for health facilities to incorporate a holistic approach to their health care services. Such an approach would ensure the outcome of the health services focus on the patient and his family by considering all their needs. By proving a conducive environment, hospitals and rehabilitation facilities enhance a patients quality of life. In Emmas case, the hospital admitting her should have ensured the hospital facility and the rooms of sensitive patients such as Emma are located in a secure location with minimum irritants. Due to dysarthria developed as a result of the stroke, Emma had difficulties in communicating and the people around could not understand her. This challenge plagued her both in the medical facilities and in the community. While in hospital, it would have been pivotal if all concerned parties collectively participated in Emmas speech and mobility therapy.It would have encouraged self-dependency in Emma by motivating her. Their collaboration would make it easier and faster to understand Emmas communication attempts. While back in the community, Emma found it difficult to relay information to others effectively and she was even occasionally misunderstood. Such scenarios could have been mitigated by the use of a SBNC approach that sensitized the community on how to take care of stroke patients. Additionally, Emmas family would be able to accompany her at times and help her around. The outcome of this approach will be a community that is united in the health and general well being of stro ke victims. Promotion of self-efficacy is among the main principles underlying SBNC. Individuals under SBNC need to be self-dependent and in control certain aspects of their health and healing process Family and health care professionals play a great part in eliciting positivity and self-efficacy in a patient. This was however not the case in Emmas journey. Emma frequently felt dependent on the medical staff for her day to day routine activities to a point she felt helpless and that the health professionals dominated her life. This feeling of dependence manifested itself even after she was released from hospital whereby she felt useless in her parents house. Her twin sister further reminded Emma of the life she had before she suffered the stroke. The society must also be involved in supporting stroke patients. Incidences such as people directing piercing looks or avoiding Emma in the pool should be mitigated to cultivate self-confidence. An effective SBNC approach would ensure that those around Emma such as the nurses, her family, and other people in the community elicit positivity. This positive attitude would, in turn, reflect on Emma and give her an inner drive to take charge and responsibility of her health and healing journey (Resnick, 2011). Conclusion In conclusion, it is important to ensure the individuals have a sense of purpose and are adequately empowered to make their own decisions.SBN can help achieve patient and family empowerment, health promotion, and partnerships in Australian healthcare by facilitating a healthcare system in which the community is actively involved and sensitive to patients and their needs. SBN considers the resources and strengths possessed by the individual and his family and uses these strengths to alleviate the existing deficits and problems. Organizations such as the Borrondara Stroke Support Group (BSSG) and the National Stroke Foundation enhance strength-based care in Australia through their various events and activities. These interventions collectively work to promote the well being of stroke patients, enhancing their resilience, and softening their suffering. SBNs guiding principles of collaborative partnership, relational care, empowerment and movement, person and family-centered care, and ho listic care provide hope, partnership, self-efficacy and empowerment to stroke victims in Australia. References Donohoe, J., 2015. Implementing an Education Programme and SOAP Notes Framework to Improve Nursing Documentation. Enable Me. (2017). View blog post. [online] Available at: https://enableme.org.au/Users/Profile/My-Blogs/View-Blog?blogId=bdb81b99-54ea-454f-b675-38dbeffe6730 [Accessed 16 Oct. 2017]. Gandolfi, M., Smania, N., Bisoffi, G., Squaquara, T., Zuccher, P. and Mazzucco, S., 2014. Improving post-stroke dysphagia outcomes through a standardized and multidisciplinary protocol: an exploratory cohort study.Dysphagia,29(6), pp.704-712. Gee, E. (2017). Reinventing Emma Gee: the inspirational story of a young stroke survivor. [online] The Sydney Morning Herald. Available at: https://www.smh.com.au/good-weekend/reinventing-emma-gee-the-inspirational-story-of-a-young-stroke-survivor-20160225-gn3gtf.html [Accessed 16 Oct. 2017]. Gottlieb, L.N., 2012.Strengths-based nursing care: Health and healing for person and family. Springer Publishing Company. Gottlieb, L.N., Gottlieb, B. and Shamian, J., 2012. Principles of strengths-based nursing leadership for strengths-based nursing care: A new paradigm for nursing and healthcare for the 21st century.Nursing Leadership,25(2), pp.38-50. Havens, D.S., Wood, S.O. and Leeman, J., 2006. Improving nursing practice and patient care: Building capacity with appreciative inquiry.Journal of Nursing Administration,36(10), pp.463-470. Heraldsun.com.au. (2017). Its a national emergency. [online] Available at: https://www.heraldsun.com.au/leader/inner-east/stoke-victim-emma-gee-and-national-stroke-foundation-campaign-for-funding/news-story/6c407833ddbecb3c3a48ee980e157f52?nk=f912a35e21d1840990b886ac7098c437-1508130786 [Accessed 16 Oct. 2017]. Hope 103.2. (2017).Recovering From A Stroke At Age 24 - Emma's Story Of Courage Hope 103.2. [online] Available at: https://hope1032.com.au/stories/life/inspirational-stories/2016/recovering-from-stroke-young-age-24-emmas-story/ [Accessed 16 Oct. 2017]. Kobau, R., Seligman, M.E., Peterson, C., Diener, E., Zack, M.M., Chapman, D. and Thompson, W., 2011. Mental health promotion in public health: Perspectives and strategies from positive psychology.American journal of public health,101(8), pp.e1-e9. Lietz, C.A., 2007. Strengths-based group practice: Three case studies.Social Work with Groups,30(2), pp.73-87. Melbourne, T. (2017). Clinical Guidelines (Nursing) : Nursing documentation. [online] Rch.org.au. Available at: https://www.rch.org.au/rchcpg/hospital_clinical_guideline_index/Nursing_documentation/ [Accessed 16 Oct. 2017]. Resnick, B., 2011. The relationship between resilience and motivation. InResilience in Aging(pp. 199-215). Springer New York. Rosamond, W., Flegal, K., Furie, K., Go, A., Greenlund, K., Haase, N., Hailpern, S.M., Ho, M., Howard, V., Kissela, B. and Kittner, S., 2008. Heart disease and stroke statistics2008 update.Circulation,117(4), pp.e25-e146. Wells, G., Shields, L., Hauck, Y. and Bennett, E., 2014. Do we make a difference?: Parents' and nurses' experiences of using a strengths-based, solution-focused approach to care.Australian Journal of Child and Family Health Nursing,11(2), p.5.

Shogun Finance Ltd v Hudson an Example of the Topic Business Essays by

Shogun Finance Ltd v Hudson by Expert Prof Nelly | 23 Dec 2016 The case of Shogun clearly demonstrates the consequences of a fraudulent buyers acts. It presents the conflicting interest of parties in good faith after a fraudulent buying and selling by a crook. In addition, it clearly makes evident the importance of weighing the conflicting interests in order that justice is delivered in the end. More importantly, it leaves a clear responsibility on both seller and buyer to ensure the veracity of the buyers and sellers identity and intention. Need essay sample on "Shogun Finance Ltd v Hudson" topic? We will write a custom essay sample specifically for you Proceed The case primarily involves a contract involving the buying of a Mitsubishi Shogun car from a car dealer of a man who was found to be a crook afterwards. The dealer phoned Shogun Finance Ltd. to determine the truthfulness of the identity of the man and his potentiality in acquiring a car for instalment. The man presented himself as Mr. Durlabh Patel and gave his drivers license as a proof of his identity. The financing company checked through electronic searching the credit background and the authenticity of the existence of the said name. Afterwards, the car was given to the man at a price of 22,250 on a hire purchase agreement. University Students Very Often Tell EssayLab professionals:How much do I have to pay someone to make my essay in time?Essay writers recommend: Find Brilliant Papers For Sale HereCheap Writing Services Write A Paper Best Essay Writing Service Write My Essay For Me Cheap Eventually, the man offered the car to a particular Norman Hudson who was involved in car alteration at a price of 17,000. The finance company then filed a suit against Hudson for damages and tort of conversion for buying the car from the man known as Mr. Patel. It was soon discovered that the man who originally bought the car stole Mr. Patels drivers license and his signature for the completion of the contract. In defence, Mr. Hudson asserted the he acquired the vehicle in good faith in accordance with section 27 of the Hire Purchase Act 1964. Section 27 of the Act provides; this section applies where a motor vehicle has been bailed under a hire purchase agreement and, before the property in the vehicle has become vested in the debtor, he disposes of the vehicle to another person. It further states; Where the disposition referred to in subsection (1) above is to a private purchaser, and he is a purchaser of the motor vehicle in good faith, without notice of the hire purchase agreement , that disposition shall have effect as if the creditor's title to the vehicle had been vested in the debtor immediately before that disposition. However, in the resolution of the case, the high court dismissed the appeal of Mr. Hudson and decided in favour of Shogun. In dismissing the appeal, the court concluded that there was no hire purchase agreement and that Mr. Hudson is not a debtor. Hence he is not covered by the exemption as provided in the act. The decision, however, have attracted some criticisms because the court has not settled the problem caused by such circumstance. On the part of Mr. Hudson and other third party in a contract, it is necessary to check the veracity of the seller and the circumstances surrounding the goods to be bought. The title is very important factor that should be ensured in buying a car. Aside from good faith, the buyer should extend extra effort in ensuing that the car to be bought is not a subject of a fraudulent contract. It is necessary to anticipate and deter future problems by clarifying matters at the very beginning. On the part of the finance company, it is necessary that the identity of the buyer or purchaser be verified by additional means. In such a kind of business, the existence of fraudulent purchasers should be anticipated, like in the present case. Hence, it is necessary to apply additional method in checking the background of the purchaser. Aside from electronic checking, the personal appearance should also be required in finalizing the transaction. This could possibly avoid forging signatures. In addition, the identification cards required should be those bearing the pictures of the person named in the card. Looking into the context of the decision, it could be concluded that the decision is unfair on the part of the innocent buyer. While it may be true that the finance company have acted in good faith, the decision could have been rendered upholding both the good faith of both. It is clear in the case that both are innocent and in good faith when they entered into the contract. Thus, it could have been favourable to both when the first contract have been found to be voidable and gave chance to Mr. Hudson and the finance company a compromising contract. Interestingly, the case of Phillips v. Brooks may be applicable in the present case. In this case, a good title has been transferred to the innocent purchaser after the establishment of a presumption that the previous contract involved a face-to-face transaction. If Mr. Hudson could have established such, there could have been a chance to attain the exemption provided in the Act. Furthermore, it is quite unconvincing that the court found the Mr. Hudson, an innocent purchaser totally liable without finding fault on the part of the finance company and the dealer. Notably, it has been recognized in the case and in several cases that the dealer was the way by which the crook perfected his fraudulent acts. It is therefore justifiable that both innocent parties should bear the liabilities instead of leaving alone to the innocent purchaser. With regard to joint liabilities, it could be applicable to adopt the Law Reform Acts of 1935, 1943, and 1945 which deals with joint tortfeasor, frustrated contracts, and contributory negligence, respectively. Instead of merely relying on the logic of law and on common law, it would be justifiable when new law reforms protecting the victims of fraud be enacted and implemented. By looking at the result of the decision, Mr. Hudson has been burdened by the disarrays of law which may happen again in the future. At this point, it should have been repaired by an outstanding decision. It is noticeable that both Mr. Hudson and the finance company are in good faith. They both believed the truthfulness of the offer made by the man who was found to be crook. However, in weighing as to the responsibility of verifying the person of the man, it is the finance company that has the greater responsibility. As a creditor, it is necessary to ensure the company that the debtor is capable of paying by checking not only the credit standing but also the income capacity of the debtor. More importantly, there should be identity investigation to ensure that the person is not misrepresenting himself to the detriment of the company. The finance company should have more method to ensure itself as to the reliability and credibility of the debtor or purchaser. Thus, it could have been more justifiable when the liability has been equally pided between the finance company and Mr. Hudson. Interestingly, there has been conflict as to the declaration of the contract as void and the identity of the man. It was said that the contract should be declared void when the signature has been forged. However, the forgery was not fully established as it was not fully found that the man was not really Mr. Patel. In such a case, it should have been presumed that contract is valid and the exception could have been extended to Mr. Hudson. But it was not the case. Nevertheless, the decision is still found unfair because of the failure to distribute liabilities among parties who acted in good faith. Bibliography Philips v. Brooks, 2 KB 243 [1919]. Shogun Finance Ltd v Hudson [2001] EWCA Civ 1001. Shogun Finance Ltd v Hudson. University College Cork. Available from http://www.ucc.ie/law/restitution/archive/englcases/hudson.htm> [14 December 2008].