IBM History

IBM or International Business Machines is a well-known  American computer manufacturer, founded by Thomas J. Watson (born 1874-02-17). IBM is also known as Big Blue after the color of its logo. The company has made everything from mainframes to personal computers and has been immensely successful selling business computers. The Beginning of IBM On June 16, 1911, three successful 19th-century companies decided to merge, marking the beginnings of IBM history. The Tabulating Machine Company, the International Time Recording Company, and the Computing Scale Company of America joined together to incorporate and form one company, the Computing Tabulating Recording Company. In 1914, Thomas J. Watson Senior joined CTR as CEO and held that title for the next twenty years, turning the company into the multi-national entity. In 1924, Watson changed the company’s name to International Business Machines Corporation or IBM. From the beginning, IBM defined itself not by selling products, which ranged from commercial scales to punch card tabulators, but by its research and development. IBM History of Business Computers IBM began designing and manufacturing calculators in the 1930s, using the technology of their own punch card processing equipment. In 1944, IBM together with Harvard University financed the invention of the Mark 1 computer, the first machine to compute long calculations automatically. By 1953, IBM was ready to completely produce their own computers, which began with the IBM 701 EDPM, their first commercially successful general-purpose computer. And the 701 was just the beginning. IBM History of Personal Computers In July 1980, Microsofts Bill Gates agreed to create an operating system for IBMs new computer for the home consumer, which IBM released on August 12, 1981. The first IBM PC ran on a 4.77 MHz Intel 8088 microprocessor. IBM had now stepped into the home consumer market, sparking the computer revolution. Outstanding IBM Electrical Engineers David Bradley joined IBM immediately upon graduation. In September 1980, David Bradley became one of the original 12 engineers working on the IBM Personal Computer and was responsible for the ROM BIOS code.

Martin Luther King, Jr Essay - 1153 Words

After Being Dragged out of their homeland, brought to an unknown country, and forced to be slaves, African-Americans saw a road trip to equality through the eyes of Martin Luther King, Jr. Even after being emancipated from slaves to citizens, African-Americans were not ready to wage the battle against segregation alone. The weight which African Americans carried on their back, was lightened when they began to see what Martin Luther King, Jr. brought to the table against segregation. Martin Luther King, Jr. was the single most important African-American leader of the Civil Rights Movement and was responsible for dramatically improving the chance of equality for African-Americans. Martin Luther King, Jr. was the key individual, which helped†¦show more content†¦Kings speaking ability increasingly improved over time. At the time, No one knew that attribute would propel him to the forefront of the Civil Rights Movement. On December 1, 1955, Rosa Parks, one of the leaders of the local branch of the National Association for the Advancement of Colored People [NAACP] refused to give up her seat to a white person on a segregated city bus in Montgomery, Alabama, despite being reprimanded by the driver (Schulke 166). Montgomery, Alabama was known for its terrible treatment of blacks. The buses in particular had been a source of tension between the city and black citizens for many years (Schulke, 167). As a result of refusing to give up her seat, Rosa Parks was arrested. Rosa Parks popularity among the black community, proved to be the spark that ignited the non-violent Civil Rights Movement (Norrell 2). For more than a year, the African-American community in Montgomery successfully boycotted the city bus company, Montgomery City Bus Lines, which resulted in the loss of much needed revenue to support the city expenses. The Bus Boycott was the impetus for many whites to act violently towards African Americans in Montgomery. Being an avid member of the NAACP, King became much involved in the boycott. Kings non-violent approach towards the boycott obviously drew a lot of attention. Kings home in Montgomery was firebombed by openly racist members of the Ku Klux Klan [KKK] (Norrell 1). Seeing that the busShow MoreRelatedMartin Luther King Jr.867 Words   |  4 Pagespeople, one of them is Martin Luther King Jr. He made the world a better place for black citizens by doing non-violence movements and marched the way to freedom. Martin Luther King Jr. was born on January 15, 1929, in Atlanta Georgia as Michael King Jr., but changed his name to Martin Luther King Jr. in honor of Protestant Martin Luther. Through his activism, King played a pivotal role in ending the legal discrimination of African American citizens. During his childhood, Martin Jr.’s father stronglyRead MoreMartin Luther King Jr1194 Words   |  5 Pagesï » ¿ Simmons 1 Gabrielle Simmons Mrs. Fitzgerald Social Studies 8A 4/27/10 Martin Luther King Jr. Martin Luther King Jr. is a well known and an inspiring man to all cultures of the world. King was and still is one of the most influential heroes. King s views and believes helped African Americans through the 50 s and 60 s to the rights and liberties that was their right. King faced many obstacles on his journey, things like jail and even assassination attempts. Despite these obstacles,Read MoreMartin Luther King Jr.1078 Words   |  5 PagesMartin Luther King, Jr., was a very strong person, constantly fighting for what he believed in, which was equality for African Americans. He was not scared to stand up and tell the world what he wanted for society. He was fearless and did everything in his power to prove a point. Martin Luther King, Jr., was the strongest individual of his time, for he fought until death, which proves how much he was willing to risk his life to make the world an equal place. Growing up, he had a very interestingRead MoreBiography of Martin Luther King, Jr745 Words   |  3 PagesMartin Luther King, Jr. (January 15, 1929-April 4, 1968) was born on in his mothers parents large house on Auburn Avenue in Atlanta, Georgia. He was the second child, and was first named Michael, after his father. Both changed their names to Martin when the boy was still young. King JR was born into a financially secure family middle class with that, They received better education in respect to most people of their race. King Jr, noticed this and this influenced him to live a life of social protestRead MoreEssay on Martin Luther King, Jr.591 Words   |  3 PagesMartin Luther King, Jr. Martin Luther King, Jr. was born at home on Tuesday, January 15, 1929 in Atlanta, Georgia. His parents were Martin Luther, Sr. and Alberta King. He was born into a world where segregation was the law. Where his boyhood best friend, who was white, wasnt allowed to play with him once they started school. Where black people went to separate bathrooms, drank from separate water fountains, couldnt eat in whites only restaurants, and had toRead MoreMartin Luther King Jr.1144 Words   |  5 PagesMartin Luther King Jr. (January 15 1929-April 4, 1968) Brief Summary (of who MLK Jr. is): Martin Luther King Jr. was a Baptist minister and an activist who led the civil rights movement in the 1950. He was a fundamental force behind the civil rights movement that ended legal segregation. He was awarded the Nobel Peace Prize in 1964. But he was sadly assassinated in 1968 on a second floor balcony of Lorraine Motel in Memphis, Tennessee†¦ Childhood: Martin Luther was never poor. He lived with a middleRead MoreMartin Luther King Jr.2405 Words   |  10 PagesMartin Luther King Jr. was a Baptist minister and social activist, who led the Civil Rights Movement in the United States from the mid-1950s until his death by assassination in 1968. IN THESE GROUPS NOBEL PEACE PRIZE WINNERS FAMOUS PEOPLE WHO DIED IN 1968 FAMOUS PEOPLE WHO WENT TO PRISON FAMOUS CAPRICORNS Show All Groups 1 of 19  «  » QUOTES â€Å"But we come here tonight to be saved from that patience that makes us patient with anything less than freedom and justice.† —Martin Luther King Jr. Read MoreMartin Luther King Jr. Essay1862 Words   |  8 Pagesbut the content of the character,† (Martin Luther King Jr,1963) Martin Luther King Jr. was a smart child and had a good childhood. He learned values from his parents, and Martin Luther King Jr was a man of much wisdom during his time. He was a major contributor to the civil rights movement, and those contributions have profound effect even today. Michael Luther King was Martin Luther King Jr’s name when was born. His parents changed his name to Martin Luther King when he was just a young boy. TheyRead More Martin Luther King Jr. Essay637 Words   |  3 Pages Martin Luther King, Jr. was perhaps one of the most influential person of our time. As the father of modern civil rights movement, Dr.Martin Luther king, Jr., is recognized around the world as a symbol of freedom and peace. Born January 15, 1929, King was the son of an Atlanta pastor. King accomplished many achievements during his life. He graduated from Morehouse as a minister in 1948 and went on to Crozer Theological seminary in Chester, Pa., where he earned a divinity degree. After that KingRead MoreThe Legacy of Martin Luther King Jr.1123 Words   |  4 PagesMartin Luther King Jr. (January 15, 1929 - April 4, 1968) was known as an activist and a remarkable leader for African Americans throughout the Civil Rights Movement. He was put in jail for his non-violent civil rights campaigns, spoke out for racial justice, and tried to find an end to racial discrimination. King’s legacy is still known present day, and continues to be one of the most well known leaders. Throughout Martin Luther King Jr.’s lifetime and the Civil Rights Movement, King was devoted

Research Proposal Larvae Therapy Free Essays

Natalie Merrier Student nurse yr Declaration of interest: I have chosen to investigate this topic as I have only worked with one patient using lave therapy treatment (contained) and was often designated the task of redressing and watering the lave, this particular gentleman did not mind the therapy and referred to the lave as â€Å"his little friends† I could not help but wonder f he wound have been so compliant if they were loose in his wound and if this would have made any difference to the healing process. Abstract: This article plans to compare the use of contained or caged maggots to those placed directly onto the wound bed itself (referred to in this research proposal as free range). All care has been taken to ensure that patient safety comes first and if at any point a healthcare professional feels that the treatment is not affective for the patient they will be excluded from the research and commenced on a more suitable or preferred treatment. We will write a custom essay sample on Research Proposal Larvae Therapy or any similar topic only for you Order Now I expect to find in my results that free range maggots are more effective, however patient tolerance will be better with contained lave due to fear of lave escaping the dressing and sensation if overlapped onto healthy skin. Introduction Maggots, many recent articles comparing debasement versus maggot therapy. Less information available on the application of maggots and how that effects the treatment and effectiveness of the maggots ability to debris, disinfect and stimulate healing. Rotational method of free range maggots Vs.. Contained maggots in gauze or muslin bags. Validity and reliability Lit review/background â€Å"Accounts of maggots used on open wounds date back to the Old Testament. † (Bare 1931; Peachtree and Sherman 1983) Bear 1931, treated a WWW soldier on a battlefield using maggots for a femur fracture and abdominal wound. Observed that the wounds were covered in maggots, after cleaning the wounds noticed that the wound bed consisted of healthy granulating tissu e. U to this he began studying maggots and there effect on open wounds in detail and pioneered the international treatment of skin infections with childhood fly rave in 1931 it was deemed safe, effective and economical at this time and was widely used until 1950 when antibiotics and surgical debarment therapy became more popular treatment option as suggested by; (Apothecaries Education Research Foundation [BETTER], 2003; Fleischmann, Grabbers, Sherman, 2004; Maggots on wounds have been used for Debarment, disinfection, stimulation of healing and billion inhabitation and eradication. Although these benefits have use particularly useful in pressure ulcer treatment and diabetic foot ulcers. As suggested y Bear (1931), Horn Cob and Gates (1976) Sherman (2002), Stevedore (2004) and -rampant (2007) Research has been conducted into the sub-species of maggots that is most effective by: REFERENCE And also research has been conducted into patient tolerance of the treatment by: REFERENCE However, less research has been done to see if patient tolerance and containment are directly related, and the extent that containment hinders the debarment process. Sample Inclusion and exclusion: No participant’s with services sepsis or gangrene and need amputation (due to the risk of patient) one of the sample group shall be diabetic as this will affect the rate of healing and cause results to be skewed. For the same reason the wounds on each patient must be about the same size and depth with equal quality of tissue (ox. CM 70% slough, for example). To keep my research fair and ethical I intend to select clients of similar age and health for a fair opportunity for contained and free ranged maggots. Due to the nature of this research in intend to select 6 patients and use 3 for each option as long as they consent and tolerate the treatment. Hypothesis/predicted results: I predict that although â€Å"free range† maggots will be more effective at debarring the wound quickly, suggested to be more effective in previous research articles Stevedore P, Jacobin CE, Osama a study conducted in the Netherlands. Wimp Fleischmann, Martin Grabbers (2004) patient preference will lie with contained or caged lava, in addition suggested that the staff applying the dressing would generally prefer the contained lava to free ranged ones. METHOD: (quantitative) statistical numerical data, comparing contained to free range goats on open wounds and infected skin tissue. (Quantitative) survey of the experience for the patient using contained or free range maggots, the combination of both meaner that I will use a triangulation method. To determine the patients feelings towards the treatment I will provide a simple questionnaire. To determine the effectiveness of the treatment itself the wounds will be measured every 2 days when the dressings are removed to give water to the maggots with a photo at start and finish helping distinguish the improvement of quality of tissue in the wound bed. Analysis Evaluation Results Ethics Patient aware of research? Know they are able to opt out of experiment at any time? F maggot treatment no longer suitable MET will recommend stopping the maggot treatment and using alternative therapy such as surgical debasement. References Bare, W. S. (1931). The treatment of chronic storytelling with the maggot (larvae of the blowfly). Journal of Bone and Joint surgery, 13, 438-475. 8. Bare WAS. Sacra-iliac Joint?arthritis deformations?viable antiseptic in chronic storytelling. How to cite Research Proposal Larvae Therapy, Essays

Charitable Trusts in Ireland free essay sample

One of the most significant changes made by the Charities Act 2009 came in s. 39 of that Act, which established a ‘Charities Regulatory Body’ to regulate charities. Case law still largely defines ‘charitable purpose’. The main advantage of being classified as a charitable purpose trust is that many of the disadvantages which would apply otherwise can be avoided; the rule against perpetuities doesn’t apply (although the trust must vest in a perpetuity period); the rule against having non-human beneficiaries can be ignored; and certain tax exemptions accrue. The case of Christ’s Hospital v Grainger was the case in which it was held that a gift over from a charity to a charity isn’t subject to the rules against perpetuities. The Cy-Pres jurisdiction of the Courts allows them to get involved to monitor charities so if their purpose changes or the charity comes to an end it allows orders to be made about the property so that it is used for a purpose as similar as possible to the purpose of the original charity. Definition of ‘charity’: The old legislation in this area didn’t set out a definition, but the preambles set out examples of what might be considered charitable purposes; the Courts expanded this definition based on ‘the spirit of the preamble’. There are four categories of charitable trusts set out in Pemsel’s Case by Lord MacNaughton. These are trusts for: 1)The relief of poverty; 2)The advancement of education; 3)The advancement of religion; 4)Other purposes beneficial to the community. There was always a difficulty with the fourth factor given its possible very wide scope. Therefore the 2009 Act sets out a list of purposes that are encompassed in the fourth category in s. 3(11) (e. g. protection of the environment). In Ireland and England, in order for a trust to qualify as ‘charitable’, it must not only serve one of the above purposes, but it must also serve the public benefit, and pass the ‘public benefit test’. The list is not intended to be exhaustive. In England they have s. 2 of the Charities Act 2006 to define charitable purposes. The 2009 Act includes e. g. voluntary work, urban regeneration, advancement of art, culture heritage or sciences etc. hich are clearly very broad categories. Trusts for the Relief of Poverty: The obvious questions raised by this category are how poor must the beneficiaries be, and how many of them must there be. In this context, ‘poor’ is a relative term; in the Re Colthurst case, it was said that in this context, poverty doesn’t mean destitution, but instead the idea of people having to go short having regard to their status. This case concerned a trust for the benefit of orphans and widows of bank officials who were in poverty. In the case of Re Segelman, a trust in favour of ‘needy relatives’ was upheld as being charitable; it was acknowledged that most of the members of the class weren’t affluent but needed help from time to time. However, the Court did limit the number of beneficiaries here, since the class was not to be closed until twenty one years after the testator’s death, and although at the time of death there were only twenty six individuals in the class, in twenty one years it would expand greatly, and the Court found that it cannot have been the intention of the testator to give gifts to after-born issue. In the Histed Article, the author is particularly critical of this wide definition of ‘poor’, as it means that the Courts have come close to saying that an occasional problem of expenditure exceeding income qualifies someone as ‘poor’, which is not a good approach. It should be noted that these trusts must benefit a class of individuals, as if they benefit named individuals they qualify as private, and not charitable, trusts. In terms of the ‘public benefit test’ in the context of this category, the test has been reduced â€Å"almost to vanishing point† according to Hanbury, because of the advent of poor employee and poor relative cases. The case of Re Scauisbrick concerned a small class, which were the needy relations of the testator’s sons and daughters. Lord Evershead said that the cases concerning ‘poor relations’ can be justified on the grounds that the relief of poverty, no matter whose poverty it is, is an altruistic act and is thus of public benefit. In the case of Dingle v Turner, a trust had been established to benefit the poor retired employees of a firm. The House of Lords upheld this trust as charitable, with Lord Cross saying that a class of over six hundred individuals was not too small to qualify as a charitable trust. However the issue with this case was that the issue of the definition of ‘poor’ wasn’t addressed. The important thing therefore when setting up a charitable trust for the relief of poverty is to benefit a class, not individuals. Issues with the area are still the fact that ‘poverty’ is ill-defined, and the public benefit test is not rigidly applied. The advent of the Charities Act 2009 has altered the position in Ireland in relation to poor relatives and employees cases, since it specifies that trusts will not be upheld as charitable where there is a close connection between potential beneficiaries and the testator; this close connection includes where they are close relatives and employees, and so in Ireland it is doubtful that such trusts will be upheld in future. Trusts for the advancement of education: The concept of what is ‘educational’ in order to qualify a trust as legally charitable has often been debated. In England there are two possible approaches. The first can be seen in the case of Re Shaw, which concerned the will of George Bernard Shaw. It stated that the trustees have to provide for research inter alia into the advantages of reform of the alphabet. Harman J stated that â€Å"if the object be merely the increase of knowledge that is not in itself a charitable object unless it be combined with teaching or education† so the gift was not upheld. The second can be seen in Re Hopkins Will Trusts a more expansive interpretation of ‘education’ was put forward by Lord Wilberforce. A gift to a society to help them search for the Bacon-Shakespeare manuscripts was held to be valid. Lord Wilberforce disagreed with Harman J saying that the word ‘education’ should be extended beyond teaching, although he did accept that research of a purely private matter would not be educational. In this jurisdiction in In re the Worth Library Keane J commented that he felt the approach in Hopkins was a lot more reasonable. This case concerned a library in a hospital. The Court rejected the idea that it fell under the category of educational as only three people had access to it and so this is taking this beyond the already liberal meaning. However, it was still upheld as charitable as it was adjudged to come under the fourth Pemsel category of other purposes beneficial to the community. The case of Oppenheim v Tobacco Securities Trust Co. Ltd concerned a trust for the education of children of all of the employees and former employees of a company. This case was a very important one in clarifying the public benefit aspect of charities for the advancement of education. It was held that the trust must fail because the distinguishing quality of the class of beneficiaries was a relationship with a named propositus, and they were not a section of the public per se. This has been a heavily criticised decision. It was noted by Lord Cross in the later Dingle v Turner case that the motivating factor behind the decision might be the ‘undeserved fiscal immunity which would be the result of finding charitable status’. Quite possible this issue will be reassessed in the next appropriate case. The case of OConnell v Attorney General concerned a trust to give money to the male descendants of the testator’s brother to obtain professions (through university education). It was held not to be charitable, because it clearly failed the public benefit test, nor could it be upheld even to a limited extent as it breached the rule against perpetuities as no beneficiary may have been alive at the testators death, and they could stay in education ‘to obtain a profession’ as long as they wanted, and there was no limit to the number of them there could be. In Magee v Attorney General High Court a broad approach towards the meaning of education was taken by Lavan J. Lavan J stated that the activities carried on in the local community school which largely consisted of the running of self-help groups must be deemed educational in nature. Trusts for the advancement of religion: This is a very complex and uncertain area, dealing with such a sensitive issue. Section 3(4) of Charities Act 2009 provides that â€Å"it shall be presumed, unless contrary is proved, that a gift for the advancement of religion is of public benefit’. Section 3(5) provides that Charities Regulatory Authority can’t make a determination that gift for advancement of religion is not of public benefit without the consent of the Attorney General. Section 3(6) provides that a charitable gift for advancement of religion shall have effect and shall be construed in ‘accordance with the laws, canons, ordinances and tenets of the religion concerned’. Finally, section 99 provides that a person who sells mass cards other than according to an arrangement with recognised persons shall be guilty of offence. Gifts to ecclesiastical office holders: The important distinction to draw in this area is that a gift for the benefit of the incumbent of an ecclesiastical office for the time being is charitable, while a gift to the particular individual who happens to hold that office will not be. In the case of Gibson v Representative Church Body, a bequest to the chaplain of the Rotunda Hospital and his successors was upheld as charitable; however, a bequest in a codicil to that same will for the chaplain’s personal benefit was not charitable. In Donnellan v ONeill a bequest to a cardinal absolutely and for his own benefit was held to be a gift to him in his private capacity, and thus not a charitable gift. The test was described by Kindersley VC in Thornber v Wilson as being whether the testator designates the individual as such, or as being the person who happens to fill the officeâ€Å". Gifts for the celebration of masses: This was a particularly common area of benevolence in Ireland over the centuries, and thus there is a fairly large body of case law concerning it. It is certainly a charitable purpose, and was designated as such by s. 45(2) of the Charities Act 1961, but it is an area which for a long time provoked considerable uncertainty and controversy. Historically the legal principles applicable differed considerably between England and Ireland. The question of the charitable nature of the gifts for the saying of masses, and whether it was necessary to specify that they be said in public, was resolved by the Irish Court of Appeal in the case of OHanlon v Logue. Here, a testatrix devised and bequeathed her property on certain trusts and then on trust to sell it and invest the proceeds and pay the income thereof from time to time to the Roman Catholic Primate of all Ireland for the time being for the celebration of masses for the repose of the souls of her late husband, her children and herself, the will containing no direction that these masses be said in public. The Court of Appeal upheld the charitable nature of the gift and made it clear that a bequest for the saying of masses, whether in public or not, constituted a valid charitable gift. This decision has been followed on a number of occasions, and the issue was put beyond any doubt by the enactment of s. 45(2) of the Charities Act 1961. In England, the law in this area was clarified by the case of Re Hetherington. Here, Browne-Wilkinson VC confirmed that gifts for the saying of masses are prima facie charitable, since it is for a religious purpose and contained the necessary elements of public benefit because in practice the masses would be celebrated in public. While he stressed that the celebration of a religious rite in private would not contain this essential public element, the Vice Chancellor made it clear that where either construction was possible, the gift was to be construed as one to be carried out only by charitable means (i. e. celebrated in public). Trusts for the Other Purposes Beneficial to the Community: Examples of the types of charitable purposes were set out recently in the new Charities Acts, which is a new departure. Prior to the 2006 Act in England and the 2009 Act in Ireland, this was regarded as a residual catch-all category. Interpretation of what it meant varied over the years. There were two main approaches. In the Attorney General v National Provincial and Union Bank of England case, the point was made that not all trusts beneficial to community are necessarily charitable, and you also have to show a charitable purpose, which is quite a rigid approach. A more flexible interpretation of this point was applied recently. In the case of Incorporated Council for Law Reporting for England Wales v Attorney General, it was suggested that the purpose of the trust possibly fell under education as well as the fourth category. Russell LJ held that if a purpose is shown to be of sufficient benefit to the community, it is prima facie charitable; here it was held to be so by the Court of Appeal. This was a much less strict approach, which made it easier to qualify. A case which is helpful in setting out the scope of this area is the Northern Irish case of Re Dunlop. It should be noted that in England and Northern Ireland, the 1st category of poverty relief included the purpose of ‘help of the elderly’ with it, as happened in this case. It involved a request to found a home for elderly Presbyterians; the Court concluded that this was a charitable purpose, and the fact that the beneficiaries were only allowed to be Presbyterians didn’t negative the fact that this was still of public benefit. The judge seemed to be taking view that it’s actually quite difficult to qualify under the 4th category, and made obiter statements that to qualify, there should be no limitations to the gift that would prevent the public as a whole from benefiting. Therefore, in this fourth category, the public benefit test seems to be tricter than in any of the other categories. Is the test for ‘public benefit’ objective or subjective? The Courts in Ireland have generally held that it is subjective, with due weight given to the viewpoint of the donor, provided it is not illegal or immoral, while the Courts in England and Northern Ireland have held it’s an objective test. In the important Irish case of Re Cranston, Lord Justice Fitzgibbon and a majority of the Court of Appeal held that it should be a subjective test, based not on the view of the judge, nor on general public opinion. Instead, the benefit must be one the founder believes to be of public advantage, but it must be rational, and not contrary to law or morality. In the English case of Re Hummeltenberg, a gift was made to a College for the training of Mediums, which was held not to be a charitable purpose. The Court looked at the Irish case law, but said that it should be a matter for the Court to decide, which is an objective approach. The Irish approach was reaffirmed in the case of In re the Worth Library. Important legislative changes took place with the coming into force of the Acts†¦s. (11) lists purposes ‘a’ to ‘l’ under the fourth category, but it is not an exhaustive list. It included two factors which hadn’t arisen in case law: the protection of the natural environment; and the advancement of environmental sustainability. It contains no mention of the advancement of human rights after much debate on this topic during its drafting, especially since this is a factor in the English equivalent of this legislation, which contains these factors in s. 2(2). Subsection (h) in the English legislation discusses human rights. A purpose included in the English Act, but not in the Irish Act, is (g), the advancement of amateur sport, which is proving very controversial. The areas mentioned in the Irish Act are: (a)Gifts for the elderly and sick: In the case Re Robinson a gift for people over the age of sixty five in a certain area, was upheld as charitable; (b)Gifts for the sick and hospitals: In the case of Re McCarthy’s Will Trusts, Budd J upheld as charitable gifts to a charity promoting trips to Lourdes for sick people. An important Supreme Court decision was given in Barringtons Hospital v Valuation Commissioner, in which a hospital sought to challenge the loss of its exemption from ratings tax, saying it was charitable. Kingsmill Moore J said that these trusts are charitable, and it didn’t matter that the hospital charged some people. In the case of In re the Worth Library, the library facilities were only available for three people, but Keane J said it as still charitable because it gave them a haven in which to relax, and that meant the whole hospital benefited. (c)Gifts for sporting and recreational purposes: In Common law jurisdictions, gifts to promote a sport are not charitable usually, but providing general recreational facilities can be charitable sometimes. In the 1950’s in England, the Recreational Charities Act was introduced, which deemed as charitable recreational facilities provided in the interest of social welfare; this legislation spawned many cases. In Guild v IRC, a testator left a gift to be used in connection with a sports centre, and the House of Lords said that this was a charitable gift; they said that the facilities for recreation did improve people’s quality of life, even if the people who benefited were not in a position of relative social disadvantage. There was a Northern Irish decision along same lines in Springhill Housing Action Committee v. Commissioner of Valuation, in which a community centre was upheld as charitable. There was only one Irish case until recently which was Shillington v Portadown UDC, where it was held that it was a valid charitable gift to give money to the local council to build facilities to encourage healthy recreation. In the relatively recent case of National Tourism Development Authority v Coughlan, there was a gift to a golf club, but this was for the promotion of a particular sport, and so was not charitable according to Charleton J, who held that the more exclusive the enterprise, usually the less likely it is to have as its sole purpose the betterment of society in general. d)Gifts for the benefit of animals: The case of Armstrong v Reeves concerned a gift to a charity for the abolition of vivisection, which was regarded as a charitable purpose under the fourth miscellaneous charitable purpose; this case was decided in the late 19th century. The issue was seen again in the 1940’s in the National Anti-Vivisection Society v IRC case, but here the House of Lords performed a balancing exercise, and said that the benefit to humanity outweighed the cruelty to the animals, and thus the purpose of the trust was held not to be charitable. e)Gifts for political purposes: It has long been established that a gift for an existing political party is not charitable; in Re ni Brudair, a gift to the benefit of ‘Republicans to advance their cause as it was between the years 1916 to 1920’ was too vague, and the Court said that it had a political objective and thus was not charitable. There is a grey area in the area of human rights. The case of McGovern v Attorney General is an important one in this area. Here, Amnesty International was trying to set up another organisation to promote human rights in other countries through diverse political means. The Judge said that this new organisation couldn’t be charitable because they were going to try to achieve their goals by changing other countries’ laws. He said that using such methods could not be charitable. This approach has been criticised because it constitutes a very broad ban on any donations to political organisations constituting charitable gifts. This decision had also been criticised in the Hanbury and Martin textbook, since it introduces double standards, as existing charities already campaign for political change, but ones seeking charitable status to do so cannot; this is an inconsistent approach.