Strategic Operations Management Som Marketing Essay

Strategic Operations Management Som Marketing Essay Strategic operations management (SOM) isnt only about how an organisation manages effectively its day-to-day activities. Furthermore, it provides the organisation with long-term objectives as well as strategic decisions and actions to achieve those objectives. (Slack et al., 2007, p.63) SOM is vital to any organisation. It is the core determinant for the organisations success because it involves every part within the organisation. Moreover, it helps organisations to achieve organisational goal and gain competitive advantages. The four advantages of operations management (Slack et al., 2007, p.22) emphasise the importance of SOM: Helps organisations reduce cost and increase the efficiency in product/service production. For Toyota case, we all recognised one its vital competitive advantage is cost; this is the evidence that SOM helps Toyota reduce cost, increase efficiency. Increases revenue by increasing customers satisfaction through good quality and service (we can find Toyota also focuses on customers satisfaction and quality) Reduces the amount of investment required for increasing operations capacity and innovative resource deployment. In a competition world, a heavy industry like automobile always has to invest on discovering the new techniques to improve and hasten production processes. Being able to reduce these costs will help Toyota give competitive price. Provide the basis of future innovation through building a strong base of skills and knowledge inside the company. This is also important, because it will motivate Toyota to develop the capability in order to adapt with possible change in the future. Besides, SOMs importance can be clarified by the Top-down perspective of the four perspectives model: Slack et al., The four perspectives on operations strategy. Operations management, 5th ed., p.64 Top-down Perspective: the starting point of operations strategy. It supports corporate, business and functional strategies of an organisation. At corporate level, we can see Toyota positioned itself to global, economic, political and social environment (Slack et al., 2007, p.63). Itll help Toyota decide: The type of business they want to do The markets in which they will operate Allocation of cash between different businesses At business level, strategic decisions helps Toyota create business strategies that related to individual business units within the organisation. The business strategy will support these business units to focus on particular customer, markets and competitors. For example when we analyse the Toyota Corporation, we find this description: Toyota runs by 3 segments: The Automobile segment designs, manufactures and sells automobiles; The Finance supports relevant financial data; and the other is responsible for housing, information and communication. (The New York Times, 2012) So, we can see SOM in Toyota attaches individual business units to the corporate strategy by formulating the goals for individual business units. At functional level, SOM make different departments recognise and hence support the business strategy. Different departments such as: operation, marketing, RD would be managed to adhere to the business objectives. Generally, lets simplify the whole points by analysing Toyota Global Vision (Toyota-Global, 2012). Here, the corporate level decision focuses on: quality, innovation and human resources. Pass to the business level, business goals and strategic decisions are formulated, then Toyota will the specific performance objectives (quality, flexibility, cost). Finally, at functional level, different departments and functions will act accordingly through various techniques (JIT, TQM, JIT) and continuous process improvement, to meet the objectives given in business level. b) To understand Toyota from different perspectives, we should use Stakeholder Analysis to identify Stakeholders expectations in associated with 5 performance objectives (Slack et al., 2007, p.39)This table describe Toyotas 5 main stakeholder groups (Toyota-Global, 2012) and their expectation. Performance objectives Stakeholder types Stakeholders expectations Quality Customer Shareholders Society Quality of product/service, safe vehicles Speed Customer Shareholders Reduce throughput time and waiting time Dependability Customer Business partners On time delivery Flexibility Customer Suppliers Toyota Availability of different models to choose from Cost Customer Toyota Lower price and superior performance Lets analyse each group in detail: Customers: Customers expectation How Toyota addresses? Meet customers expectations? Quality Toyota strives to do thing right at the first time. With Total Quality Management (TQM) Toyota controls the quality from development, procurement, production to after sale service, while focusing on continuous improvement. Yes Opportunity to feedback and receiving of the information Listening to customer, giving timely supports. Yes http://www.toyota-global.com/sustainability/stakeholders/customers/quality.html Safety and reliability Offering modern technologies and information to prevent accidents such as: virtual human model, navigation system, audible system Recent recalls of 7 millions of cars because of faulty window switches may oppose this statement (Kollewe, J., 2012) http://www.toyota-global.com/sustainability/stakeholders/customers/safety.html Low price By applying effective techniques on processes, Toyota can lower the costs, thus giving low price to customers. (JIT, Jidoka, Lean manufacturing) Yes Dependability Toyota production system (TPS) helps on-time delivery Yes Flexibility Toyota offer a wide range of product Yes http://www.toyota-global.com/company/vision_philosophy/toyota_production_system/ Employees: Employees expectation How Toyota addresses? Meet employees expectation? Safety health Creating safe and healthy working environment Yes Pride Motivate and inspire the employees to work with full energy. Yes Confidence Guarantee a stable career and secured working conditions Toyota has sacked 350 workers in Australia (OConnor, P., 2012) this may cause some tensions for current employees. Equality in all aspects Emphasize mutual respect and harmony in work place. yes Opportunity Continuous develop HR yes http://www.toyota-global.com/sustainability/stakeholders/employees/ Business partners: Partners expectations How Toyota addresses? Meet partners expectations? Equal opportunity Giving equal opportunities for all suppliers, providing clear guidelines to potential supplier. Yes Fairness in receiving information All partners are well informed Yes Long term procurement Open-door policy to encourage fair competition Yes Stable relationship Mutual benefit based on mutual trust Yes Trust Unified cooperation with partners. Yes http://www.toyota-global.com/sustainability/stakeholders/partners/#policy Society/Communities: Society/communitys expectations How Toyota addresses? Meet societys expectations? Environment preservation Development of eco-friendly models. Reduce amount of CO2 in product, manufacturing, production process Develop recyclable material, resource and product Yes Safer vehicle Produce safe vehicles to prevent accidents Not really, because of the recent recalls. Innovation in life style Motivate activities concerned in environment preservation Yes. Other automakers (Honda, Ford, Mitsubishi) are influenced to produce this kind of product. (Schulte, M., 2012) http://www.toyota-global.com/sustainability/stakeholders/society/mobility.html Social welfare Social welfare programs Yes Jobs Provide employment opportunities to unemployed. Yes Infrastructure Infrastructure development activities Yes Traffic safety Education and training Yes http://www.toyota-global.com/sustainability/stakeholders/society/contribution.html http://www.toyota-global.com/sustainability/stakeholders/society/environment.html Shareholders: Shareholders expectations How Toyota addresses? What Toyota prioritises? ROI Sustainable profitability Respect for the agreements Respect and follow the laws Support the long-term vision for management Dividends and shares Dividends based on investment plans, business results, cash revenues http://www.toyota-global.com/sustainability/stakeholders/shareholders/ In addition, Globalisation has considerable influence on Toyota strategic operations management activities. Globalisation comes with plenty of opportunities as well as challenges (Slack et al., 2007, p.680). With the help of internet, Toyota can easily be available to worldwide customers, procurements and other transaction activities will become internet-based, which helps reduce cost and enhance quality control. Lets identify what challenges and opportunities of globalisation for Toyota: Greater competitions, wider range of customers demands, and partners around the world. Higher customers awareness and expectations Global value chains increasing complexity competition Higher knowledge of culture, behaviours is required Higher requirement of technology applications. Continuously increase of product standards Require more efficient and effective supply chains Require continuous improvement and innovation Having a clear view on the influences of stakeholders and globalisation to Toyota, we can clarify the SOM in different perspectives: Product/service perspective SOM in Toyota focus on transferability of products/services (Slack et al., 2007, p.681). This means Toyota guarantees their design compatible with different hobbies and attitude of customer throughout the world. Here, Toyota considers widening range of options to cope with different cultures and customers, the RD department will be commanded to design according to the customers expectation. The five performance objectives should be focused at the business level of strategy to gather and maintain customers loyalty. Toyota guarantees a reliable quality in every product with competitive price in order to satisfy customers expectations. Provide safety and reliable vehicles that inspire enthusiasm at affordable prices. (Toyota-global, 2012) Relationship with suppliers and other partners is important. Since its establishment, Toyota has sought to work closely with its suppliers in its manufacturing activities (Toyota-Global, 2012) Hybrid car is a good innovation and should be developed as it meets both customers and societys demand. Toyotas unique hybrid system combines an electric motor and a gasoline engine in the most efficient manner. It saves fuel and reduces emissions while giving ample power. (Toyota-Global, 2012) Manufacturing perspective Toyota should emphasize the quality in every product to enter global market. The TQM at Toyota is to ensure this. To compete with other automakers around the world, Toyota always find the ways to reduce costs, yet guarantee an acceptable quality. Again, the importance of partnership is justified, in associated with continuous development on: waste reduction, stock control, human skills, capacity planning and control, process improvement, etc. For example, Toyota pioneers the Lean manufacturing concept, a production method that focuses on reducing waste. Specifically, Toyota use common parts and designs for multiple product lines and reducing the number of suppliers, so that Toyota can buy parts and components at greater number, with lower cost. (Ann All, 2010) Localizing manufacturing makes Toyota effectively deal with different markets around the world. Now there are 51 bases in 26 different countries and regions. In addition, there are design and RD bases in nine locations overseas (Toyota-Global, 2012] Toyota should always make continuous improvement. Flexibility and dependability should be noticed in the manufacturing arena. Layouts of facilities need to be adjusted properly with the culture of particular region. Process technology development should be emphasized. Here availability of skills, serviceability and maintenance options can be exploited (Slack et al 2007 p681) Capacity and inventory planning and control are other areas to consider. Here Toyota JIT is helpful Administrative perspectives Toyota respects the different cultures and beliefs. Toyota is establishing a corporate culture with abundant vitality by fostering human resources that include a diverse range of individuals. (Toyota-global, 2012) Job design should be considered in globalisations. Here cost of labour, skill availability, cultural should be considered. (Slack et al., 2007, p.681) Business recovery plan should be developed to minimize the damage on reputation caused from risks. Supplier management should be considered to increase quality, and reduce cost. Toyota may develop knowledge management to increase knowledge base within the organisation. Environmental-friendly is highly considered in Toyota Because of the globalisation, Toyota may face the increases of new competitors, new products, low pricing, better quality. So, its important to promote continuous improvement principle, whilst avoiding errors (quality problem, employee sacks) as these will damage companys reputation. Task 02 For big organisations, global capability mostly came from their capability in manufacturing (Pepsi, Coca-cola). Then, Toyota would be also such case, as their success has been considerably contributed by manufacturing functions. (T., Ohno, 1988) shared a story about the strange growth at Toyota though many companies were suffering the economic recession. The operation way of manufacturing function was included in TPS. The two main concept of this system include Jidoka and Just-in-Time: where Jidoka guarantees of product quality through the prevention, in-time correction, and Just-in-Time is about reducing waste and speed enhancement in work processes. (Toyota-Global, 2012) Generally, Toyotas global capability came from the continuous development of various long-term objectives: TPS, efficient use of resource, human skills, waste reduction, customer focus, supplier network improvements, emphasis on quality and customisation, inbound logistic management, inventory control For clarifying the Toyotas competitive advantages, lets analyse through the five performance objectives (Slack et al. 2007, p 39) Performance objectives Competitive advantage How Toyota did it? Quality High quality The Jidoka helps prevent possible errors of product. The Lexus series are carefully done from the design, production, procurement, to the service delivery for customers. Good quality helps reduce the re-works, lessen the confusion, thus increase dependability, efficiency and reduce cost(Slack et., al, 2007) Speed Quick delivery Toyotas JIT principles, inventory control and inbound logistics management helps enhance the speed of production and delivery. The speed emphasis helps Toyota reduce inventories and risk (Slack et al., 2007) Dependability Reliable delivery Again, the JIT, planning and control systems help Toyota to provide on-time delivery, both to internal production process and customers. This helps Toyota increase efficiency operation, saves the time, money and gives stability to the company.( Slack et al 2007) Flexibility Production flexibility Mix flexibility Volume flexibility Delivery flexibility Wide range of product Toyota develops variety of attractive and practical models such as: Camry, Prius, Varis Toyotas R D division often design different models to satisfy different markets. Toyota is able to adjust the volume in production process. Toyota even can reschedule the manufacturing priorities. It would help the organisation to become agile, maintains dependability, and saves time. ( Slack et al 2007, p 47) Cost Low price Perhaps price is the strong competitive advantage of Toyota. Price is very important in automobile industry. However, effective cost reduction has been helping Toyota to provide favourable price. This make Toyota the leader producer in automobile industry. The performance objectives in Toyota could be illustrated by this polar diagram: Adapted from Slack et al., Operations management (2007), p.55 Besides, identification of the customers needs and expectations should be critical considered. Therefore, the order winning factors and qualifying factors could be appropriate to identify the competitive advantage of Toyota. Order winner is customers key reason for buying a product/service, while qualifying factor is the minimum competitive factors required to get the attention from customers (Slack et., al, 2007, p.69.). For Toyota the order winning factors include: standardized quality and design, low price, and dependability. Qualifying factors are: wide range of products, quick throughput-time and quick delivery to customers (speed) Adapted from Slack et al., Operations management (2007), p.69 In addition, different customers and markets have different expectation, so these factors would change according to that. For example, Lexus is a luxury series of Toyota, its target market is higher income people, therefore, the order winners would be: high quality, gorgeous design and qualifying factors are: acceptable price, quick delivery and reliable delivery. Task 3 Analysing the operation strategy at Toyota through Top-down perspective, we see that corporate level strategy lead the organisation to long-term objectives such as: innovation, waste reduction, continuous improvement Business level concentrates on performance objectives such as quality, cost, flexibility and dependability, and adapts the strategy according to the corporate objectives. And at functional level, different functions (manufacturing, RD, marketing) plan, execute and cooperate steps to achieve business objectives. These are evidences of how effective Toyota pursues its long-term objective: Toyota applies TQM, Kanban, JIT in production to achieve performance objectives. At the product/service segment, Toyota focus on innovation, quality and customer care (Toyota Code of Conduct, 2006, p.12) Finally, at administrative perspective, Toyota pays attention to: sustainable location decisions, long-term capacity management, continuous resource development and long-term supplier relations (Toyota Code of Conduct, 2006, p.12)). Here, we should notice that supplier relationship is important; Toyota should manage the first and second-tier suppliers effectively to work globally because advantages come from the close relationship with suppliers (Slack et al., 2007) These following concepts can be helpful to analyse Toyota Operation Strategy: Product Life Cycle (PLC) Product Life cycle Source: Marketing FAQ,What is Product Life Cycle(PLC)? 1. Introduction stage In introduction stage, when something new is introduced in the market, competitors will be few. Companies should develop flexibility to adapt with changes in the market (Slack et al., 2007) For example with Toyota case, a new great model Prius Hybrid has just entered the market. Assume it is in introduction stage, then customers who purchase this model would be innovators. This model seems to be well designed in shape and technology, so competitors are few, but may not exclude big competitors such as Mercedes, BMW, GM Then, the order winning factors here should be the design and qualifying factors should be quality, price. That means, Toyota should focus on design, and pay attention to quality and price. 2. Growth stage This stage is characterised by sales volume and competitors increase. The objective should be keeping up with demand expectations and ensuring the quality (Slack et al., 2007) Toyota will compete with competitors, order winners will be quality, speed and dependability (deliver according to the demand) to cope with increasing demand, and satisfying factors will be price and flexibility. We recognise that Toyota offers a wide range of product and price for different markets customers in order to attract different market segments. Lets take the case of Toyota Camry 2012, currently it is in growth stage and the target market is average income people. Its facing a rough competition with Honda Accord, both companies emphasize the quality. Though the quality, design, performance is somewhat similar, Honda is slightly better than Toyota. However Toyotas offering variety of same type products such as: Matrix, Sienna, Avalon providing more options for customers, which may yield more profits. (Halvorson, B., 2012) 3. Maturity stage In this stage, the demand has a sign to fall; some competitors withdraw from the market exclude big players. The concentration should be turned to price reduction. Here, company has to deal with cost, production and supply issues (Slack et al., 2007) Toyotas target customers now should be the mass market. Then, order winning factors will be low price, and dependability of supply. The qualifying factors are flexibility (various types of model) and quality. A wide range of product may bring some profits as Toyota already had different target markets. Consequently, Toyota should focus on cost reduction, dependability and expansion of market. We can see how Toyota applies this practice by the example of Lexus: Lexuss in maturity stage, which explains Toyotas efforts to offer a wide range of models: sedan, hybrid, SUVs which we can find in the link below: http://www.lexus.com/models/allVehicles/ 4. Decline stage Decline stage is characterised by: sales decline, more withdrawal, price competition and cost focus. (Slack et al., 2007). Here, customers are the people who follow new style late, and competitors will be less. Price war will happen and obviously, order winning factors will be low price, qualifying factors are dependability of supply. At this stage, Toyota should focus on reducing costs. Lets look at the Toyota Qualis model which had gone to the decline stage and it was replaced by the Innova. Toyotas trying to replace with Innova, probably they will sell the remaining Qualis with low price. (TNN, 2005. The Economic Times) Efficient frontier Toyota might use this approach to position its main performance objectives in order to achieve effectiveness in operation (Slack et al., 2007). With Toyota, the high variety will make the cost higher. There are some ways such as: innovation of sustainable products, increasing product life in the PLC, positioning of product at various stage in the PLC could help Toyota limit variety. In Toyota case, there are quality, cost and variety that need to be considered properly to increase the efficiency of product Adapted from Slack et al., Operations Management, 2007, p.78) Toyota can link the frontier approach with PLC to make rational decisions. Different PLCs stage requires different concentrations, Toyota may adjust its variety/quality/cost accordingly to adapt with the situation. For example, suppose Innova model reached Maturity stage in India, then Toyota would focus on cost reduction. Since Indians only prefer family car like Innova, variety should be ignored. Consequently, Toyota should sacrifice Variety to achieve cost efficiency. Toyotas competitive advantages overview Kanban System A unique method developed by Toyota. Here, JIT and Lean manufacturing are applied effectively. This method helps Toyota develop the production process speed and efficiency. Therefore they can avoid inventory, waste of resources, product error and other unwanted costs. Kanban system provides some benefits such as: waste reduction, inventory avoidance, error-free manufacturing, which help Toyota produce quality products with low cost, increase their competitiveness over other automakers. (Toyota-Global, 2012) Relationship with Suppliers Toyota understands the importance of having strong relationship with suppliers. As an integral part of Kanban system, suppliers are always up-to-date with new changes in Toyota. A lot of investments were done by Toyota to extend its supply network. As a result, Toyota is one of the organisations possess strongest supplier network in different areas of the world. The principal measure of supplier relations in the American auto industry is the OEM benchmark Survey that is published by John Henke of Oakland University. Suppliers rank auto manufacturers using 17 measures from trust to perceived opportunity. In the 2003 survey Toyota ranked first followed by Honda and Nissan, while Chrysler, Ford and GM were fourth fifth and sixth. The survey also showed that Toyotas scores had improved over 7% over 2002. Another automotive supplier survey published annually comes from J.D. Power. The 2003 survey found that Toyota, Nissan and BMW are the best North American automakers in promoting innovation with their suppliers. (David McBride, 2004) Valuable culture As a Japanese organisation, Toyotas management is highly concern with Japaneses culture. Here, the loyalty and pride is highly respected. Besides, Hofstedes 5 cultural dimensions shows Japanese is characterised by highly regarding hierarchy authority, uncertainty avoidance and long-term orientation. This leads to these following results: Employees willingly follow the command from managers, so the decision making process and the implementation of decision will be faster. The employees strive to get to perfection due to the high uncertainty avoidance. Every worker has their pride of their work, so they wont damage their own credibility. Long-term orientation leads every individual in the organisations to continuous development and perfection. These cultural benefits made employees at Toyota continuously develop themselves thus get better performances. Because of this, the cultural value is considered one of Toyotas strongest advantages. Task 4 Lets apply the SWOT analysis for the overall review on Toyota Favourable Unfavourable Internal Strengths Strong global presence Strong brand image Strong financial performance Effective marketing and distributions to different market segments. Toyota production system Continuous improvement and innovation Strong relationship with partners Weaknesses Heavily relied on imports for inputs Heavily depends on Japan and U.S. market. Recent recalls in 2010 External Opportunities Increasing demand for hybrid electric vehicle Enough capability to produce more quality, green, fuel efficiency products. Opportunities in Asian market. Threats Increase competition from other automakers. Uncertain economic condition Usual demand is gradually changing, due to the environmental and fuel price issues. Recommendation Toyota should focus on their hybrid technology as the demand increases and pay attention to green technologies. Thanks to their reputation of quality and innovation, these concentrations can help Toyota get an additional competitive advantage. The Build your Toyota is a great innovation; customers can customize their own model. http://www.shopatgst.com/gstbuildyourtoyota/default.aspx?zip_code=70000Vehicle=nullYear The RD section should always be invested properly as it will keep Toyota up-to-date with modern technologies. Note in mind that now the green, fuel efficiency technologies are most concerned with the society. Keep promoting its brand in key markets, and in new-developed countries such as Russia, China, Brazil, and India. The demand in these markets is increasing due to the improvement of quality of life. Governments of China and India have reduced taxed for automobile, this may be the chance for Toyota. Keep observing the competitors, while focusing on the quality factors to avoid mishaps (2010 recalling) that damage their reputation and market share. Toyota should consider applying vertical integration in the growing markets and improve the management of different portfolios. Conclusion As the leading manufacturer of automobiles market, Toyota has all the required conditions to continue their successful journey in the future. Though there are currently some disadvantages, Toyota can still improve by taking more responsibility in community, environment and society. References: Ann All, (2010). Did Lean Manufacturing Contribute to Toyota Recall? IT Business Edge. 29th Jan., 2010. [online]. Available from: [accessed 5th Oct., 2012] David McBride, 2004. Toyotas Extended Lean Enterprise. EMS Consulting Group. 1st Dec., 2012. [online] Available from: [Accessed 5th Oct., 2012] Halvorson, B., (2012). Toyota Camry Vs. Honda Accord: Compare Cars. The Car Connection. 11th Sep, 201. [online]. Available from: [Accessed 4th Oct., 2012] Kollewe, J., (2012). Toyota recalls 7m cars worldwide over window fault. The Guardian. 10th Oct., 2012. [online]. Available from: [Accessed 12th Oct., 2012] OConnor, P., (2012). Toyota Australia sacks 350 workers. World Socialist Web Site. 17th Apr., 20

Reflecting on Practices in Medicine Administration

Reflecting on Practices in Medicine Administration The ability to become reflective in practice has become a necessary skill for health professionals. This is to ensure that health professionals are continuing with their daily learning and improving their practice. Reflective practice plays a big part in healthcare today and is becoming increasingly noticed. Administration of medicines is a key element of nursing care. Every day some 7000 doses of medication are administered in a typical NHS hospital (Audit Commission 2002). So throughout this essay I will be evaluating and highlighting the learning that took place whilst on placement at a day unit. Drug administration forms a major part of the clinical nurses role. Medicines are prescribed by the doctor and dispensed by the pharmacist but responsibility for correct administration rests with the registered nurse (OShea 1999). So as a student nurse this has become my duty and something that I need to practice and become competent in carrying it out. Each registered nurse is accountable for his/her practice. This practice includes preparing, checking and administering medications, updating knowledge of medications, monitoring the effectiveness of treatment, reporting adverse drug reactions and teaching patients about the drugs that they receive (NMC 2008). Accountability also goes for students, if at any point I felt I was not competent enough to dispensing a certain drug it would be my responsibility in speaking up and let the registered nurses know, so that I could shadow them and have the opportunity to learn help me in future practice and administration. The reflective model I have chosen to use is Gibbs model (Gibbs 1988). Gibbs model of reflection incorporates the following: description, feelings, evaluation, and conclusion. (Gibbs 1988). The model will be applied to the essay to facilitate critical thought, relating theory to practice where the model allows. Discussion will include the knowledge underpinning practice and the evidence base for the clinical skill, that I have learnt and supporting this with available literature. Description The first stage of Gibbs (1988) model of reflection requires a description of events. I was asked to administer a drug to a patient named in hereafter as Mrs. A for confidentiality purposes (NMC 2008).I had observed this clinical skill on a number of occasions and had previously administered medication under supervision. On this occasion I was being observed by two qualified nurses, one of which was my mentor. The drug had been dispensed and was ready to be administered and Mrs. A consented to have a student administer the medication. My mentor talked me through the procedure step by step, and informed me that they have struggled with Mrs. A and her compliance with medication before so I should keep an eye and ensure that she swallows her medication and that she does not keep it her mouth. The medication that Mrs. A is on is Clozapine. The decision to use clozapine is not taken lightly because of the potentially life threatening side effect. An awareness of side effects is important to primary care practitioners because they have most contact with the patients. I learnt that using anti-psychotics is just a component of a holistic approach to a patient with psychotic illness and that care should also include psychological treatments and social care. Mrs. A does not have any issue with the drug it self but with the staff, as she is in a very psychotic state. Service users have requested strategies from services providers to manage the risk of using psychiatric medication to inform their choice about which psychiatric medication to use (DOH,1999). However evidence suggests that, there is choice, but generally by practitioner experience (Hamann et al. 2005). In non compliance of medication I had to encourage Mrs. A to make her choice to take the medications and that it was in her care plan and as part of her treatment. A nurse who has built a good relationship with a patient by informing and empowering them will be in a strong position to have a non judgmental conversation with them about the importance of adherence (Mc Lellan. 2009). My thought and feelings I was aware of being under the supervision of two qualified nurses and this made me feel very nervous and self conscious and I had to ensure that I was doing everything correctly and that I made no errors. Once my mentor questioned my practice, concerning if I knew the side effects of the drug I was about to administer, I became even more aware of feeling nervous and under pressure. The patient was present and I did not want the patient to feel that I did not know what I was doing. So I had to ensure before administering that I was giving the medication to the right patient and at the correct dose that it was at the right time and route. All of these had to be done to guarantee that I am competent in my ability to administer medication under the supervision of a registered nurse. This also gave me the opportunity to carry out this task in order to achieve this so I could get it signed off by my mentor in my essentials skills cluster. The nurse patient relationship is by many considered the core of nursing. This can be done to build a good relationship and rapport with patients (Framer.et al 2001). When I was first orientated to the ward, I took it upon myself to read the patients notes so that I had more insight to the patients and their illness and index offences if any. After this I went and introduced myself to the patients because it is vital that the patients are aware of who I am and my status if I am to provide nursing care for them. (Berlo, 1960) puts great emphasis on dyadic communication, therefore stressing the role of the relationship between the source and the receiver as an important variable in the communication process. Evaluation Administering medication and how this combined with care, compassion and communication forms the bases of a holistic approach to care, and with the knowledge I got from supporting literature formed the foundation of my learning and practice. Burnard (2002) suggests that a learner is a passive recipient of received knowledge, and that learning through activity engages all of our senses. Reflective practice is becoming an essential skill that is incorporated into clinical practice and CPD and it is therefore important that the nurse understand the role and the potential of reflection. Different ways to reflect in practice can be approached; however, there are evident barriers to reflection within a care setting including time because of the busy environment a hospital encompasses or lack of motivation if the vast majority of health care practitioners are not undertaking it. The NHS has to implement ways in which all healthcare professionals can reflect in their practice to enhance patient care, as one of the NHSs main aims is to improve the care of patients.

robert frost :: essays research papers fc

Moraru Teodora-Bianca IIIrd year, German-English gr. I. The Psychological Origins and the Effects of the Hobbyhorse in Laurence Sterne’s â€Å"Tristram Shandy† Defying Dr. Samuel Johnson’s statement that â€Å"Nothing odd will do long†, Laurence Sterne’s eccentric masterpiece, â€Å"The Life and Opinions of Tristram Shandy, Gentleman†, an extended act of meditation upon story-telling based on John Locke’s philosophical theory of the association of ideas, became a notable forerunner of the modern English novel, celebrating the infinite possibilities of the art of fiction. Undoubtedly, one of the most crucial philosophical literary works of the 18th century was John Locke’s â€Å"Essay Concerning Human Understanding†, which had a tremendous influence on the writers of his time and also on the worldwide approach to terms such as â€Å"the nature of thought† and â€Å"human consciousness†. In his â€Å"Essay†, Locke stated important theories about the sequence of ideas and their interrelation, which profoundly influenced Sterne and became the basis of much of the seemingly arbitrary structure of his comic metanovel, â€Å"Tristram Shandy†. Sterne adopted in particular two of Locke’s concepts. First, the association of ideas, by which certain ideas, either by accident or because they have some particular significance, become so closely linked in a man’s mind that he cannot think of any of them without inevitably calling up all the others as well, in the same order in which he had prieviously experienced them. Secondly, the train of ideas, which is a more general concept of the mind as being constantly in motion, with the result that one idea automatically suggests another in some way similar to it, which in turn leads on to something else. Sterne uses this latter concept as an explanation for much of the seemingly eccentric behaviour of his characters and as a basis for many of the dazzling transitions of time and space which take place in the novel. John Locke considered the ideas as being the fundamental building blocks of all human thought, also stating the fact that â€Å"all our knowledge and ideas arise from experience† and that there are no innate ideas. He viewed the human mind as a â€Å"tabula rasa†, a â€Å"white paper, void of all characters, without any Ideas†. This empty room of the mind is gradually furnished with ideas of two sorts: first we obtain ideas of things we suppose to exist outside us in the physical world by sensation, and secondly we come to ideas of our own mental operations by reflection.

Business Education Essay -- essays research papers

Argumentative Draft Formal Education Is the Key to Success   Ã‚  Ã‚  Ã‚  Ã‚  The advancement of technology in the last decade has increased the demand for Americans to seek higher and formal education. No longer do we live in the age of manual labor, family owned & operated conveniences, but rather a computerized age. Thirty-years ago job seekers could find stable and secure work that would ensure stability and a prosperous future. Those white collar jobs could be obtained and secured by individuals lacking a formal and/or higher education. Today, blue collar jobs like fast food restaurants, warehouse labor, and/or janitorial services prefer and sometimes require some form of education. Employers have become more openly concerned about their employees ability to represent their companies. (Formal education is the key to empowerment, but it is not necessary in order to become successful in today’s society.)   Ã‚  Ã‚  Ã‚  Ã‚  Education has become a large importance and often the determining factor for competitive job seeker. More than half of Americans citizens seek some form of education at one time or another whether it be for job placement or advancement. Technology is always changing and requires employers to train and re-train its employees to keep then afloat. College students like myself have always been for warned that higher education is the key to ensure success in the career world and will be the only means of providing a competi...

Essays --

Throughout John Fitzgerald Kennedy’s life, he left behind not only a â€Å"household name† but also an American legacy. Both his name and face are recognized all across the United States as a legendary icon who touched every heart and every mind in America. From the day JFK was born, May 29, 1917, to the tragic day of his assassination on November 22, 1963, he completely inspired and earned full trust from the citizens of America. John F. Kennedy (also known as â€Å"Jack†) did not have the average childhood. He grew up in a very wealthy, very political Catholic family. His parents had high hopes for all nine of their children. but actually aspired for John’s older brother to become president. However, after the untimely and tragic death of his older Navy brother, he took his parents dreams for him upon himself. His political career began when he ran for Congress in Massachusetts in 1946. Not long after serving as the senator at 36 years old he was married to Jacqueline Bouvier. John became extremely popular not only because of his age, but he was also a popularly published author. His wor...

Defining Social Media Essay

In my opinion, social media is used to keep in touch with people, share ideas, videos, and pictures, and gain some knowledgeable information in networks and virtual communities. Social media is very handy when it comes to keeping in touch with long-lost friends and family members. Social media is a great resource to search things that you don’t know and that allows you to become knowledgeable about things you needed to know. Article Selected: Vine’s Biggest Teen Star Criticized for Homophobic Video Response: My response to this article is that you should always watch what you put on social media because anything can be saved and it could generally be held against you depending on what the post may be about. Social media isn’t always a person’s best friend. You need to watch what you post; especially for employer reasons. Majority of employers will go onto your Facebook page and see what kind of a person you really are. In this certain article, Nash Grier is a very popular person on Vine. After he posted the video making a homophobic slur, he did delete it because of negative comments that started to begin. The trick to this though, is that he deleted it, but someone else had already saved it and posted it again and it went viral. After that, Nash Grier did take it upon himself to apologize on Twitter saying how he was being ignorant, stupid, and how he was stuck in a bad place. He may have apologized, but from here on out, it’s possible that this discrimination will be held against him for life, due to one mistake he didn’t think about before he posted it on social media. Conclusion: Think before you post. You should always know that whatever you post on social media, may or may not affect you in the long run. Be smart and think about what you’re posting before you actually submit it. Citation: Vine’s Biggest Teen Star Criticized for Homophobic Video. (2014, July 8). Retrieved February 2, 2015, from http://articles.chicagotribune.com/2014-07-08/entertainment/sns-201407081348reedbusivarietyn1201259209-20140708_1_vine-civil-wars-social-media

Legal perspective on Human Trafficking

Hence, â€Å"censorship† would be referred as an act, policy, decree to censor the Eddie. Censorship has always take an important role in history that deemed to suppress freedom of expression across different era. Early signs of censoring could be traced back into ancient societies. For instance, following the well-known story of Socrates being sentenced to drink poison during Greek empire, the Romans has treated censorship as an honorable task and recognized Its importance In shaping individual characteristics.On the other hand, looking Into the current China, there Is no surprise that the 1st China censorship law can be recorded as early as DADDY. Censorship is served for different purposes across the time-line of human 1 5th century, which is in contrast towards another purpose of enhancing the influence of Soviet Socialist Republic in Russian empire during 20th century. Its reasoning could be depending on nature of authority and its relation with citizens as well as the va lues of society itself.Despite the past is shadowed by censorship, demagnification of societies in modern days have become the cornerstone in realizing freedom of expressions. Countries in northern Europe, such as Sweden are frontiers that has made attempt to abolish censorship through introducing a law that guarantees freedom of press in 1766, which followed by Denmark-Norway in 17708. Meanwhile, the enforcement of first Amendment of the Constitution of the United States (1787) is regarded as the root of the comprehensive protection on freedom of expressions.However, in Malaysia context, censorship has remained upon today as important tools to 1 Oxford University Press, Oxford Advance Learner's Dictionary (7th Eden, POP 2005) 237. 2 Oxford, Oxford Advance Learner's Dictionary (n 1) 3 Meet Newt, ‘The long history of censorship' (Beacon for freedom, 2010) accessed November 2013. 4 Newt, ‘The long history of censorship' (n 3) 5 ibid 6 Army . Taft, ‘Censorship of film , broadcast and Internet' (Bibliophile Alexandrine, 2004) accessed 26 October 2013. Newt ‘The long history of censorship' (n 3); Sheldon S. Woolen, Politics and Vision: Continuity and Innovation in Western Political Thought (Princeton University Press, 2004) 8 Newt ‘The long history of censorship' (n 3) 9 ibid control and regulate various media to ensure there is no illicit materials to be spread among society. As a result, various Free Speech institutions have regarded Malaysia s a low scorer in freedom of expression.In fact, extensive censorship legislations are still enforced to regulate the As a result, various Free Speech institutions have regarded Malaysia as a low scorer in freedom of information received 1 . Due to large variety of media available, this assignment would only focus on evaluating the censorship restrictions on printing press and publication in Malaysia, particularly books, articles and printed news. Assessment will be conducted in basis of the exte nt of power, conflicts with freedom of expression as well as it effect on affected businesses. 0 Censorship in Malaysia Malaysia has fallen by 23 places to its historical lowest of 14th in 2013 because the access to information has becoming more and more limited. Within the Printing press and publication industry in Malaysia (Refer 3. 0), related parties would be subjected to few legislations enacted by government to administer the (PAPA) (Act 301) is a direct legal enforcement specifically implemented for printed media. Besides that, Sedition Act 1948 are frequently applied when dealing with dispute of censorship in printed media.On the other hand, freedom of expression offered in Judicial systems is available under Article 10 in Constitution of Malaysia. 2. 1 Printing Presses and Publication Act 1984 (Act 301) (PAPA) Its former self is known as Printing Ordinance 1948, which is introduced by British colonial government into Malaysia during the beginning of state of emergency to co unteract the threat on the establishment arising from the Communist activities 3.Subsequently, the act becomes Printing Presses and publication act at year 1971 via amendments and incorporation of Imported Publications Act 1958 (Act 63) to prevent the provocation of racial sensitivities after the race riots 0 Freedom House, ‘Malaysia' (Freedom House, 2012) accessed 22 October 2013 1 1 Article 19, Malaysia: Joint submission to the UN universal periodic review' (Article 19, 11 March 2013) accessed 12 October 2013 12 Reporters without borders, ‘2013 World press freedom index: dashed hopes after spring' (Reporters without borders, 2013) accessed 22 October 2013 13 Jimmy, ‘The Printing Presses and Publications Act 1984 (PAPA)' (CUE, 25 September 2010) accessed 10 October 2013 14 ibid of 196914. Further amendments are made to enhance the power of legislation and become today's Printing Presses and Publication Act 1984 (Act 301). The general purpose of the act is punitive measure to public immaturity, potential racial conflict, and national security.It has reconciled the use of printing process, the printing, production, reproduction and distribution of publications, and the importation of publication from abroad 5. Within the Act, there are few notable sections that greatly expand the power of censorship as well as the responsibility of Minister, which are shown as below: Figure 1: Assessment on specific proviso in PAPAYA Section 3 – internal security Minister (Minister of home affairs) has absolute secretion in granting or refuses; revoke or suspended a license at any time and reasons, for a limited period. The common practices under this section are to issue license annually. Along with granting a license, minister may impose additional conditions such as deposits, which may be forfeited when an offence under the Act is committed.Section AAA – Juridical parties do not have any powers in questioning the decisions made by minister. Se ction 7(1)- Home Affairs Minister has the qualification to ban the publication of any book. The provision does not provide a clear and objective reasons on possible bans: publication which he is satisfied contains any article, caricature, photograph, report, notes, writing, sound, music, statement or any other thing which is likely to be prejudiced to public order, morality, security, the relationship with any foreign country or government, or which is likely to alarm public opinion, or which is likely to be contrary to any law or is otherwise prejudicial or is likely prejudicial to public interest or national interest. 5 caps, Media Freedom (CAPS, 3 June 2013) accessed 21 October 2013 16 corny, ‘The Printing Presses and Publications Act 1984 (n 13) Article 8(1) – minister had the secretion to define offences through classifying it as publishing malicious â€Å"false news†. Action will take on any press outlet or publication when their writings are deemed as not taking â€Å"reasonable measures† to verify the truth of the news. Article 8 has been used frequently on critics, which successfully invoked against, 1998 – Limit Guan Eng (from TAP), for his criticism of the statutory rape case involving former Malice Chief Minister, Ihram Thumb Chick. 2003 – Irene Fernando (activist), for exposing the maltreatment of illegal migrant workers in detention camps. However the conviction was overturned on technicality in 2008 2005 – Khalid's Safari, who authored the book 50 Dali Meaning Inward Taiga Bole Jade PM 2. Malaysian Sedition Act 1948 The Sedition Act is enacted along with PAPA in 1948, serving similar purposes with PAPAYA. It is deemed to be copy of Sir James Stephens definition of what is and what is not seditious during British collaborations. Despite the communist insurgency has ended, but the Sedition Act continues to be used with full force today. As the 513 incident occurred in 1969, amendments were made throu gh Emergency Ordinance 971 to criminals any doubts noon: Part Ill (on citizenship), Article 152 (on national language), Article 153 (on the special positions of the Malay and the rights of other races) and Article 181 (the Rulers' sovereignty) of the Federal Constitution.Theoretically, sedition should be defined as the crime of revolting or inciting revolt against government or support for an enemy of a country during war time through speeches, publications or 17 curry, ‘The sedition Act 1948' (CUE, 25 September 2010) 10 October 2013 18 Adman, ‘The Sedition Act (1948)' Malaysia Today (Malaysia, 23 May 2013) accessed 21 October 013 19 Jellybean Anthony, ‘Seditious tendency? : political patronizing of free October 2013 20 US legal, ‘Sedition law & legal definition' (US legal, 2013) accessed 11 October 2013 organizational, but sedition does includes conspires to disrupt the legal operation of the government, protest government policy and is beyond expression of an opinion. However, the act is known to favors the prosecutor; meanwhile, many restrictions are imposed on freedom of expression, particularly regarding sensitive political issues. Notably, seditious would not Just to be deemed as a legal but also a lattice issue.Figure 2: Proviso extracts from Sedition Act 194822 In Section 3, seditious tendency is referred as: – to bring into hatred or contempt or to excite disaffection against any Ruler or government. – to seek alteration other than by lawful means of any matter by law established. – to bring hatred or contempt to the administration of Justice in the country – to raise discontent or disaffection amongst the subjects – to promote ill-will and hostility between races or classes to question the provisions of the Constitution dealing with language, citizenship, the special privileges of the Malay and of the natives of Saba and Karakas and the sovereignty of the rulers. In Section 4(1), it covers th e: -preparation of an action, which would have â€Å"a seditious tendency'. Speech and the printing, publishing, selling (or offering for sale), distribution, reproduction or importation of seditious materials. 2. 3 Freedom of Expression under Article 10 of the Federal Constitution of Malaysia As extracted: Figure 3: Extract of Article 1023 1 . Subject to Clauses (2), (3) and (4) † (a) every citizen has the right to freedom of speech and expression; (b) all citizens eave the right to assemble peaceably and without arms; (c) all citizens have the right to form associations. 21 Adman, ‘The sedition Act (1948)' (n 18) 22 corny, ‘The sedition Act 1948' (n 17) 23 Jimmy, ‘Article 10 of the Federal Constitution' (CUE, 24 September 2013) accessed 10 October 2013 2.Parliament may by law impose † on the rights conferred by paragraph (a) of Clause (1), such restrictions as it deems necessary or expedient in the interest of the security of the Federation or any pa rt thereof, friendly relations with other countries, public order or morality and extinctions designed to protect the privileges of Parliament or of any Legislative Assembly or to provide against contempt of court, defamation, or incitement to any offence; on the right conferred by paragraph (b) of Clause (1), such restrictions as it deems necessary or expedient in the interest of the security of the Federation or any part thereof, or public order; on the right conferred by paragraph (c) of Clause (1), such restrictions as it deems necessary or expedient in the interest of the security of the Federation or any part thereof, public order or morality. 1) may also be imposed by any law relating to labor or education. 4. In imposing restrictions in the interest of the security of the Federation or any part thereof or public order under Clause (2) (a), Parliament may pass law prohibiting the questioning of any matter, right, status, position, privilege, sovereignty or prerogative establi shed or protected by the provisions of Part Ill, Article 152, Article 153 or Article 181 otherwise than in relation to the implementation thereof as may be specified in such law. Dry.Shad Salem Affair stated that the ‘freedom' under this article is fairly weak, armorial due to â€Å"Sensitive Matters Amendment†24 that allowed parliament to enforce restrictions on eight grounds – ‘public order, national security, incitement and offence, friendly relations with other states, contempt of court, contempt of Parliament, defamation, morality'25. From other perspective, it is perceived that ‘freedom' has already been weakened during drafting stage, which subsequently failed to ensure any restriction imposed on fundamental liberties are ‘reasonable' inside the final drafted. 24 ibid (n 23) 25 Shad Salem affair, ‘Much to cheer in book ban decision' The Star (Malaysia, 10 February 2010) accessed 22 October 2013 26 Jimmy, ‘Article 10 of the Fed eral Constitution' (n 23) 2. 4 Analysis: violation on freedom of expression caused by censorship The implementation of PAPA is mainly used in dealing with licensing of publications.Under this act, much discretion power has been given to the minister to administer the contents that are allowed to be published. Although implementation of licensing on print media do not breach freedom of expression under international laws, but it is subjected to criteria below: 1 . There is no discretion to refuse license, once the requisite information has been revived; 2. The system does not impose substantive conditions upon the print media; 3. The system is not excessively onerous; and 4. The system is administered by a body which is independent of government. Obviously, PAPA are not qualified to meet criteria above as referred to its section 3, 7(1), 9(1) and AAA.International law would also allow restrictions on freedom of expression, yet it only applicable under conditions that such restriction s are provided by law, whereby the law should be accessible and not excessively vague. In contrast with international laws, Centre of independence Journalism (CUE) expressed that many he international test regarding restrictions on freedom of expression. Figure 4: International test on Sedition Act 194830 Firstly, the crime of sedition in Malaysia is extremely ambiguous to meet the standard. Both â€Å"sedition† and â€Å"seditious tendency' are loosely defined and subjective terms such as â€Å"hatred†, â€Å"contempt†, â€Å"discontent†, â€Å"feelings of ill-will† and â€Å"disaffection† are used without any precise definition.Secondly, in legitimacy test states that restrictions are only permitted on basis of fundamental right for the purpose of protecting certain aims, namely the rights or petitions of 28 Toby Mendel, Restricting Freedom of Expression: Standards and Principles (Centre for Law and Democracy, 16 September 2010) accessed 25 October 2013 29 Article 19, ‘Memorandum on the Malaysian sedition act 1948' (Article 19, July 2003) accessed 1 November 2013 30 Jimmy, ‘The Sedition Act 1948' (n 17); Article 19, ‘Memorandum on the Malaysian sedition act 1948' (n 29) others, national security or public order (order public), or public health or morals. Restrictions merely based on incidentally effect one of the legitimate aims listed would be regarded as insufficient. Lastly, for the necessity test, restrictions only can be permitted on legitimate objectives, which needs to be proportionate to outweighs the harms on freedom of expression or Justified by the benefits accrued.There should be no rational relationships found between maintaining the public order and the crime of sedition. In fact, public order could suffers when governments are shielded from criticism. In short, both Sedition Act and PAPA are crowned with considerable power to administer printed media as it's granted with excessive di scretion and its border of supremacy is further expanded with the supports from ambiguous proviso. The restrictions imposed in Malaysia are mainly targeted at the freedom of expression, unlike the international practices of restricting the restrictions that restrict the freedom of expression. Unfortunately, Article 10 does not voice out the ‘true' freedom as it is bound to restrictive measure that stipulated in so, 3 and 431.Observations show that the statements applied in these provisions share a similarity to what was written in Sedition Act. As a result, both Sedition Act and PAPA do not conflict with the constitution of Article 10, which make both legislations are legally Just in dealing tit freedom of expression. However, the legally equitable would only remain within the plain text of legislation. Proof. Dry. Andrew Aerie stated that mainstream media, such as print media have failed in their roles to inform and educate the public as well as interrogating the powered, whi ch basically caused by the ‘equitable' Sedition Act and PAPA. He further stated that civilized society recognize human beings as sentinels who are by authoritarian laws.Malaysia's authoritative censorship have been infamous across internationals, treated as an infringement against the motto of United Nation (UN) charter and the f the Federal Constitution' (n 23) 31 corny, ‘Article 10 32 Borneo post, ‘Abolish printing press and publication act' (Borneo Post, 1 April 2011) accessed 18 October 2013 33 Borneo post, ‘Abolish printing press and publication act' (n 2) 34 Lee shih-Ian, ‘UN tells Malaysia to abolish death penalty, respect religious practices and human rights' The Malaysian Insider (Malaysia, 25 October 2013) accessed 1 November 2013 35 Lee shih-Ian (n 34) universal declaration of human right. Prime Minister has been urged by United States and other UN members to keep his promise in abolishing these restrictive laws. ) A political cartoonist Gull ible Inward Haste, also known as Suzan is frequent target of Home Affair Ministry for his political sensitive works. Police have seized dozens copies of his book on the accusation of â€Å"prejudicial to public order† under Sedition Catch. Several compilations of his cartoons are banned too under PAPA ruling.Suzan has attempted to counter-attack by filing a Judicial review along with Malaysian, but the High Court in Koala Lump upheld the ban in July 201137. Again, Suzan challenged the government on the Sedition Act in later years and unsurprisingly received a lost. II) Historically, the Sedition Act has been invoked on those critical of the government, including the capability to suspend members of parliament's parliamentary immunity. As recent as year 2009, the law has been one of the main measures used to arrest those opposed to the BAN takeover of the Perk state governmental. Ill) Journalists will be sentenced for publishing â€Å"false news† under PAPA, but if both PAPA and Sedition couldn't dampen criticism, officials can resort to curb it with very powerful Internal Security Act.Government claims it is encourage self-censorship among Journalists. V) In Memorandum by Malaysian Demanding Press Freedom 2010, 3 out of 8 major violation of Press Freedom in past 52 weeks are related to print media, which includes: 1) â€Å"Inaccurate Report† by â€Å"China Press† on ‘Gasp resignation, which is clarified that its retirement is at September. 2) A New Publication Guidelines for Newspapers are elaborated but ambiguously worded 36 Bob Dietz, ‘No Joke: Malaysian October 2013. 37 ibid (n 36) 38 Report without borders, ‘Another court sides with Malaysian government against political cartoonist' (IBEX, 12 November 2013) accessed 16 November 2013. 9 Jimmy, The sedition Act 1948†² (n 17) 40 Bob Dietz, ‘No Joke: Malaysian cartoonist stands up to government' (n 36) 41 Margin, ‘Stop political intervention, self- censorship in media industry' (Lira, 10 June 2010) accessed 3 November 2013 guidelines were framed as â€Å"self-regulation†. The newspapers were reportedly instructed not to cover news related to cohabitation, adultery, homosexuality, counter-culture; and no graphics of human genitalia and G-strings. 3) Confiscation of Books l) â€Å"Malaysian Maverick: Mathis Mohammad in Turbulent Times† were confiscated and anted for short periods, contends that the fourth prime minister was responsible for losses of OROMO billion during his term in office. II) â€Å"Where Is Justice† and â€Å"1 Funny Malaysia† – published by â€Å"Malaysian† while written and drawn by Suzan.Regardless of all these issues, courts' decisions and their interpretation on both legislations remained as the primary references in evaluating the extent of freedom of expression. Entities are often being charged under both PAPA and Sedition Act by the public prosecutor for any pr inted article that regarded as unacceptable. In the ease of Public Prosecutor v Pun Chin Chignon , where the supreme court held that â€Å"false news† will not be Justified under Section 8(1) if the accused are capable to prove its efforts in verifying the truth of the news. Otherwise, freedom of expression would be restricted under Article 10(2)(a) if breached against section 8(1). In a similar case of Deputy Public Prosecutor of Malaysia v.Irene Fernando, its publication of report entitled â€Å"Abuse, Torture and Diminished Conditions of Migrant Workers in Detention Centers† are charged under Section 8 (1) of PAPA as well. Mrs†¦ Urine's civil sights are restricted as the court condemned that the reports are providing maliciously false information. It is only to be reversed by High Court Judge Mohammad Panic All after the 13 years old court battle. Both cases have illustrated that extensive proofs are needed to escape from the restrictive measures raised by the prosecutor under PAPA. Besides that, in the case Limit Guan Eng v Public Prosecutor, the appellant (Limit Guan Eng) is charged under both PAPA and Sedition Act regarding two different issues.The ‘false news' distributed in the form of pamphlet is upheld by court as luscious information, due to the fact that 19941 MAMMAL 42 43 The public eye awards, ‘Irene Fernando' (The public eye awards, 2009) accessed 28 October 2013 44 Fide, ‘Ms. Irene Fernando finally acquitted! ‘ (fled, 25 November 2008) accessed judge has chosen the dictionaries that defined the key term ‘mangos debarkation' that in favors of Section 8(1). Besides, the court clarified that protection will not be accorded to anyone charged under the Sedition Act [Article 63(4)], which overthrown the Article 63 (1) & (2). Appellant are unable to rely on reasonable efforts in verifying the truth as the Judge relied on Record of Parliamentary Debates of the House of Representatives as admissible evid ence to ascertain this issue.For the charge on Sedition Act, appellant loses his ground as Judgment favors the statement of KIP Stanley Lie made, which is corroborated by two other police officer, Karri Budding and Inspector Look Yoke Choc. Appellant are not able to prove that statement as uncorroborated. It is key evidence in determining whether the appellant's speech contained seditious words regarding the non-prosecution of an ledge rape case involving Tan Sir Ihram Thumb Chick. According to Melanin bin Abdullah & Nor v Public Prosecutor, the case has illustrated a circumstances where the publisher has a clear sign of opposing both constitutions and sedition acts.Tutu's Namely as a newspaper publisher has published a talk given by prominent Malay leader and Member of Parliament with the sub-heading of ‘Abolish Tamil or Chinese medium schools in this country'. The outrageous statements, has breached several provisions that enacted to protect public order and racial stability . Without any dissent, the court held the news as editions under Sedition Act so(1)(f) in accordance with violation of Article 152 (l)(a) & (b). Besides that, Article 10 so is applicable in restricting the freedom of expression, which aligned with Article 152, Article 153 or Article 181 . 2. 5 Final Comments Although the legislations enacted does not define or express the term ‘censorship', but the practices conducted by the authorities are indeed exhibited the nature of censorship itself.