Analysis of Prest v Petrodel Resources Ltd

Analysis of Prest v Petrodel Resources Ltd The relatively short and significant judgment in the Supreme Court case of Prest v Petrodel Resources Ltd has gathered vociferous interest from academics and practitioners. It was of key interest as it was a legal cross over between family law and company law. The legal team representing Prest stated that the decision is of major importance not only for family law and divorcing couples, but also for company law, and it is the most important reviews since Victorian times on the law regarding piercing the corporate veil.[2] The principles of lifting the corporate veil for the past eight decades seemed to have never been wholly established as judges always contradicted each other and never reached a unanimous decision. There has been extensive discussion as to whether a court can ignore the principle of separate legal personality and treat a companys property, rights and obligations as belonging to a person who owns and controls the company.[3] The critical points which would be analyse d in this essay would be whether Prest has brought us closer to what the principle of lifting the corporate veil can be defined as, what it entails or whether the whole doctrine should be set aside. It will be argued that the law should not be given its quietus as it seems that judges are somewhat getting closer to an answer. Prest narrowed the circumstances in which the doctrine may apply thus, this could show that decision makers are near the end of a long marathon. On the contrary, it seems that even if the doctrine is set aside, the principles would still be applied unknowingly by judges, it would perhaps not be defined as piercing the veil doctrine. It would possibly be applied in conjunction with other laws which would have the same effect and outcome as piercing the corporate veil. Lifting the corporate veil has been viewed narrowly to be the process used by the courts to either determine what exactly is going on behind the shell of incorporation. The whole concept of lifting the veil was derived from Salomon v Salomon[4] where corporate veil was established. It was held that a limited company was viewed like any other independent person with its right and liabilities appropriate to itself[5] The Salomon principle has been the foundation on which company law and business corporations have thrived on for years.[6] When taking into consideration how the law has developed in this area, Cheung describes that it is evident the House of Lords decision in Woolfson [7] came to be source for guidance in subsequent cases. More importantly, the HL emphasised that it is only appropriate to pierce the corporate veil where the circumstances indicate that the company is merely a faà §ade concealing true facts. However, despite this important distinction, the courts have alwa ys been wary that there must be some limit to the protection afforded by limited liability to ensure that business dealings remain honest. As Lazarus[8] explained no court will allow a person to keep an advantage which had been obtained by fraud[9] This principle underpinned all of the early attempts to pierce the veil meaning that the court will not allow a corporate personality to be used to protect individuals from wrongdoing. Similarly, Lord Sumption explains piercing the corporate veil means disregarding the separate personality of the company[10] Moreover, as per Lord Keith in Woolfson,[11] he states it is appropriate to pierce the corporate veil only where special circumstances exist[12] Consequently, right from the onset, there were conflicting views. The reception which the doctrine received forty years ago is still echoed to this day in Prest. The court reaffirmed in Prest the well-established judicial conservatism approach that the corporate veil could only be pierced in very rare cases[13] Therefore, despite the doctrine not being clear, it is well established that the doctrine is not be considered in all corporate cases but, ought to be considered only rare ones. On the other hand,it can be argued, that the strictness of the approach led to the doctrine existing more as a matter of legal theory than as a feature of legal practice. Prior to Prest, in Lipman,[14]the only way to lift the veil was if the company was regarded as a sham or mere faà §ade. In Smallbone,[15]Sir Morritt brought forward the argument that it is uncertain as to which circumstances a company can be considered as a sham or whether the company need to do something illegal for immorality to suffice.[16] Hence, this suggests that there is no clear structure to be followed. This could create further confusion as to what the doctrine of piercing the corporate veil originally intended to do. Could this perhaps suggest that it is better to abandon the doctrine as a whole rather than to try and figure out what the principle actually proposes to do. This could perhaps create more clarity in the sense that decision makers would know what is not meant to be included in the doctrine. Furthermore, this can be mirrored in Prest where Lady Hale and Lord Wilson doubted whether it is possible to classify all cases neatly into cases of either concealment or evasion[17] Therefore, even to this day there are a lot of question marks as to when and how the doctrine is applied; there are still a lot of unanswered questions which have not been dealt with. It seems that the judges only deal with these when and how it comes. It can be contended that the doctrine is there but, no one has yet connected the dots to see the full picture of what it entails. The fact that none of these questions seem to provide a clear picture further creates problems today as for a doctrine to develop or adapt to the new changes, the reasonings behind the past decision needs to be understood thus, if one cannot do that then how can the doctrine be established. Notwithstanding, since Prest, it is no longer sufficient for a company to show that it is a mere faà §ade or a sham;[18] one must show that control of the company by the wrongdoer was used as a device to conceal the wrongdoing.[19] A new provision on how the doctrine should be established was brought in Prest. Over the past eighty years, there has been many interpretations. Most recently, analysed by Lord Sumption where he identified the concealment and evasion principle. In Prest, Lord Sumption argued for a narrower and clearer approach by restricting the circumstances in which the veil may be pierced. This was because references to a faà §ade or sham beg too many questions to provide a satisfactory answer[20] He attempted to give an explanation; He stated that the veil would be restricted to two principles: the concealment principle and the evasion principle.[21] The concealment principles is the interposition of a company or perhaps several companies so as to conceal the real ac tors[22] But, he noted that this does not actually involve piercing the veil; the court is simply looking behind the faà §ade to discover the true facts.[23] Contrarily, the evasion principle applies where a person is under an existing legal obligation which he deliberately evades by interposing a company under his control.[24] However, despite the two approaches being somewhat clear; Lord Alcock observes that care must be taken because none of the other six justices of the Supreme Court agreed with Lord Sumption without some qualifications[25] He also points out that there is substantial uncertainty surrounding the operation of the evasion principle.[26] Most significantly, Neuberger also found that in cases where piercing the veil was considered, it either did not apply in the facts, or it was applied on the facts but the results could have been arrived at on some other legal basis.[27] On these grounds, this could show that the doctrine does not necessarily need to exist as the same outcome can be arrived on some other legal basis. It can be indicated that the doctrine could perhaps only exist to give reassurance to corporate businesses in order to ensure them that they have a sense of security in case something goes wrong, but in reality, it does not exist and is rarely applied. Undoubtedly, Lord Neuberger drew different conclusions regarding the application of the principle. He argued that there is not much support for the doctrine.[28] He observed that there is no English case which unequivocally underpinned a power to lift the veil[29]; however, recognition is given to a limited power as a valuable judicial tool to undo wrongdoing in cases where no other solution exist[30] It gives the impression that every judge will come up with a new principle every now and again which would be relied upon but then a couple of years after, a new judge will find criticism in the doctrine. It seems that it is going around in a vicious circle without reaching an end-po int. Additionally, Lord Sumptions principle brought further opposition. Lord Mance argued that It is dangerous to seek to foreclose all possible future situations which may arise and I would not wish to do so[31] Furthermore, it should be considered that Prest only dealt with one specific class of asset which were held by those of corporate entities. The decision shows that an application of company law principles is required when determining the ownership of those assets.[32] Henceforth, this shows that Prest only narrowed only one specific factor in piercing the corporate veil, a factor which cannot be used in all cases. This further shows that we are no closer to an answer of lifting the corporate veil. Contrarily to the above, despite there not being a set doctrine, it seems that the Lordships all agree on one aspect. In Prest, they all accepted the existence of a general common law veil piercing as being limited to rare and exceptional circumstances.[33] Lord Clarke argued that Sumptions distinction the circumstances in which the doctrine apply are rare[34] This similar reaction has been echoed in the past. It can be thus shown, that not much has changed and the decision makers are still unsure as to when the doctrine can be applied. In 2017, it is very difficult to predict what the future path for the doctrine will take as there are many conflicts on this topic even from the Supreme Court judges. As stated above, Lord Neuberger, Lord Clarke and Lady Hale were not entirely convinced on the validity of the doctrine and seeing it as merely a metaphor which was unclear and inchoherent. This was contrasted with Lord Mance and Lord Walker who are very much in favour of keeping the doct rine. On the other hand, Lord Neuberger who had initially been in favour of giving the doctrine its quietus because it had been misapplied in the eighty years indicates that the obiter by Lord Sumption is very influential and could prove to be important in future cases. Hence, this further indicates that there are still many uncertainties within the doctrine itself. It can be indicated that if Prest was successful in providing a set answer as to what piercing the corporate veil entails then there would have been many cases which would have pierced the veil post Prest. For some the most helpful case is the decision in Pennyfeathers limited v Pennyfeathers property company limited.[35] It is said to be a better example of facts for giving rise to the principle of piercing the veil. Provided that the principle was to be properly established then there is one thing that all decision makers would agree upon which would be that the company was used in an attempt to immunise himself from the liability of wrongdoing[36] This is consistent in DHN[37] just as much as it is in Gramsci.[38] It seems that in every case that involves piercing the veil, the defendants always argue that there is no such thing as piercing the corporate veil[39] thus, could it be that many wrongdoers have been able to escape liabilities simply because the doctrine was not well es tablished. The new approach found in VTB[40]and Prest significantly restrictive approach to piercing the corporate veil which in effect has relegated the doctrine to a principle of last resort.[41] Post Prest cases such as R v McDowell[42] and R v Singh[43] shows that the superior courts exercising restraint in disturbing the principle in Salomon.[44] It therefore appears that where litigants can show that the relevant tests are satisfied, the courts will allow them to obtain judgement against assets that were intentionally placed out of their reach. However, these cases are and will remain exceptional. More recently, in Akzo Nobel[45] in its arguments had suggested that the Competition Commission had tried to attribute the activities of the subsidiaries to Akzo Nobel which was in effect piercing the corporate veil.[46] It could be considered that an alternative approach would be to put the doctrine on a statutory basis so that the courts would have a guide to follow instead of consistently establishing conflicting views between themselves. However, this could prevent flexibility of the courts whilst it faces complex issues which cannot be foreseen by statute. On the other side of the coin, it would be less harmful than having ambiguous rules. Furthermore, there could be an extension which established distinct body rules for corporate groups such as in Germany. The interest of the whole group both financial and non- financial matters would be recognised. Moreover, another approach could be piercing the veil by removing limited liability towards involuntary creditors, notably tort victims. In Chandler v Cape,[47] it introduced some basis for this approach whilst imposing liability on a parent company by suggesting that the parent company has a duty to the employees of its subsidiary company. To conclude, it has been suggested by academic commentary that the decision reflects a progressive trend of restricting the doctrine.[48] However, it can be contemplated that slightly narrowing a doctrine which Supreme Court judges do not agree with does not mean that it is progressive.[49] If one keeps on rebutting every proposal that is brought forward then that is not progressive, it does not feel like any decision makers has tried to find a solution for this problem. It can be disputed that this is a never ending vicious circle.  It seems as if it is an entertaining ground for judges to see what new solution can be made this time around. Prest brings a new kind of uncertainty.[50] However, Prest does confirm that the veil would only be pierced in exceptional circumstances. There is one basis which all judges approve which is that the veil is only to be pierced in exceptional circumstances. This could perhaps be a starting point of a well-established doctrine. It can be contende d that, even if the doctrine is given is quietus, judges would still apply the principles of piercing the veil unknowingly. This decision can be derived from another legal basis but, it will have the same outcome. Thus, even if it is given its quietus, the doctrine would still be there transparently. It seems that we are at a halt with the long marathon until, a case can fully apply the two provisions in Prest. Bibliography Practitioners Textbooks Palmers Company Law Books A Digman A, John Lowry, Company Law (8th edn OUP Oxford) Birds J, Boyle Clark B et al, company Law (9th edn, Jordan Publishing) Dr Wilde C, Smith and Keenans Company Law ( 17th edn Pearson) Lowry J, and Arad Reisberg, Company Law Corporate Finance (4th Edn, Pearson Journals Akansha Dubey et al, Family Law (2014) 3(1) A Alcock piercing the veil- A dodo of a Doctrine (2013) 25 denning LJ 241,243 A Bowden Concealment, Evasion and Piercing the corporate veil: Prest v Peterodel Resources Ltd [2013], Greens Business law, April 2014 Bull S, piercing the corporate veil in England and Singapore [2014] Heinonline C Hare, Piercing the corporate veil in the supreme court (again)- The Cambridge Law Journal, 72 [2013] 511-515 Chrysthis N Papacleovoulou, lifting or piercing, the corporate veil in Cyprus: a doctrine under challenge- an analysis of English and Cyprus case Law analysis (2016) 27 (4) ICCLR D Lightman, Petrodel Resources Ltd v Prest: Where are we now? Trust Trustees (2013) 19 (9):877 J McDonagh, Piercing the corporate veil in the family division: Prest the latest from the court of appeal- Trust and Trustees (2013) 19 (2) 137 J Payne Lifting the corporate veil: A reassessment of the fraud exception Cambridge law Journal, 56 (2) July 1997 Mujih E, Piercing the corporate veil as a remedy after Prest V Petrodel resources Ltd: Inching towards Abolition [2016] Westlaw 17,17 Pey Woan Lee, The Enigma of Veil- Piercing (2015) 26 (1) ICCLR 28, 30 Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) Tan Cheng-Han, Veil piecing- a fresh start (2015) 1 JBL Online Articles Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) http:///www.spearswms.com/expert-analysis-of-the-Prest-judgment/> accessed 8th March 2017 Simon Mcleod- The Corporate Veil And Its Piercing As Clear As? http://gdknowledge.co.uk/the-corporate-veil-and-its-piercing-as-clear-as/ >accessed 20th February 2017 Cases Akzo Nobel NV v Competition Commission [2013] CAT 13 Antonio Gramsci Shipping Corp ors v Aivars Lembergs [2013] EWCA Civ 730 DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852 Lazarus Estates Ltd v Beasley [1956] 1 QB 702 Prest v Petrodel Resources Ltd UKSC 34, [2013] R v McDowell [2015] EWCA Crim 173 R v Singh [2015] EWCA Crim 173 Salomon v Salomon [1896] UKHL 1 Trustor AB v Smallbone (No 2) [2001] EWHC 703 VTB Capital plc v Nutritek International Corp [2013] UKSC 5 Woolfson v Strathclyde Regional Council [1978] UKHL 5 [1] Prest v Petrodel Resources Ltd UKSC 34, [2013] [2] Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) http:///www.spearswms.com/expert-analysis-of-the-Prest-judgment/> accessed 8th March 2017 [3] French D, Mayson S Ryan C, Company law (31st edn, OUP) 127 [4] Salomon v Salomon [1896] UKHL 1 [5] Lord Halsbury Salomon v Salomon [98] [6] Lowry J, and Arad Reisberg, Company Law Corporate Finance (4th Edn, Pearson) 35 [7] Woolfson v Strathclyde Regional Council [1978] UKHL 5 [8] Lazarus Estates Ltd v Beasley [1956] 1 QB 702 [9] Ibid [10] Prest Lord Sumption [16] [11] Woolfson v Strathclyde Regional Council [1978] UKHL 5 [12] Paragraph 90 lord Ketih [13] Prest [103] Lord Clarke [14] Jones v Lipman [15] Trustor AB v Smallbone (No 2) [2001] EWHC 703 [16] Ibid [17] Ibid [92] Lady Hale [18] Jones v Lipman [44] [19] Birds J, Boyle Clark B et al, company Law (9th edn, Jordan Publishing) 60 [20] Prest [28] (lord Sumption) [21] Pret [28] Lord Sumption [22] Ibid [23] Ibid [24] Ibid [35] [25] Alistair Alcock piercing the veil- A dodo of a Doctrine (2013) 25 denning LJ 241,243 [26] Pey Woan Lee, The Enigma of Veil- Piercing (2015) 26 (1) ICCLR 28, 30 [27] Prest [74] Lord Neuberger [28] Prest [69] (lord Neuberger) Alistar Alcock (n 18) 250 [29] Ibid [30] Ibid [31] Ibid [100] Lord Mance [32] Piercing the corporate veil in the family division: Prest the latest from the court of appeal- Trust and Trustees (2013) 19 (2) 137 [33] Piercing the corporate veil in the supreme court (again)- The Cambridge Law Journal, 72 [2013] 511-515 [34] Ibid [103] Lord Clarke [35] Pennyfeathers limited v Pennyfeathers property company limited [2013] EWHC 3530 (Ch) [36] Gramsci. Burton J [101] [37] DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852 [38] Antonio Gramsci Shipping Corp ors v Aivars Lembergs [2013] EWCA Civ 730 [39] Ibid [40] VTB Capital plc v Nutritek International Corp [2013] UKSC 5 [41] Bull S, piercing the corporate veil in England and Singapore [2014] Heinonline 39,39 [42] R v Singh [2015] EWCA Crim 173 [43] R v McDowell [2015] EWCA Crim 173 [44] Mujih E, Piercing the corporate veil as a remedy after Prest V Petrodel resources Ltd: Inching towards Abolition [2016] Westlaw 17,17 [45] Akzo Nobel NV v Competition Commission [2013] CAT 13 [46] Simon McLeod- The Corporate Veil And Its Piercing As Clear As? http://gdknowledge.co.uk/the-corporate-veil-and-its-piercing-as-clear-as/ accessed 20th February 2017 [47] Chandler v Cape plc [2012] EWCA Civ 525 [48] Akansha Dubey et al, Family Law (2014) 3(1) 214,217 [49] Tan Cheng-Han, Veil piecing- a fresh start (2015) 1 JBL 20,21 [50] Chrysthis N Papacleovoulou, lifting or piercing, the corporate veil in Cyprus: a doctrine under challenge- an analysis of English and Cyprus case Law analysis (2016) 27 (4) ICCLR 129,130

A Comparative Analysis of Early Greek Rhetorical Theory

The Rhetoric word has been derived from the Greek word Rhetor meaning speaker and meaning of the term is an art of public speaking. (Habib, 2005) The art implies various techniques applied by the speaker to create dramatic, intellectual and emotional appeal while delivering the speech. It also implies composition and arrangement of the text making it more appealing and persuasive for the listeners.Since last two hundred years, the scope and application of rhetoric has considerably changed in the changing literary, social and intellectual contexts.The art of rhetoric has been modified to meet various needs in the political sphere, in the sphere of institution and discipline of philosophy, in the institution of theology whereby rhetoric has been placed in context to the expression of divine revelation, in the entire sphere of education practices and literary criticism. In all these areas, rhetoric is placed and articulated to meet their specific interests.Rhetoric was originated in Anc ient Greece in the fifth century B.C and got into existence by Sophists, Aristotle, and then from the Roman world to Cato, Cicero and Quintilian. The father of Church St Augustine enlisted the form of rhetoric during the service of Christian doctrine.Classical rhetoric had five parts: invention, arrangement, style, memory and delivery. There is also held opinion that the art of rhetoric was founded in 476 BC by Syracuse whose student Tisias spread the teachings of this master and brought it into the main stream. All theorists and historians have acknowledged the fact that rhetoric was used profoundly in the political activities and was the most important component in democracy.The ruling powers had all the right to express independently and in an articulate way and had judged that it was only through the control of language, ideas and worldviews that a particular class could have a control over the economic and political spheres. The trend was true in our ancient and is very well pr evalent in the democratic world of today. (Habib, 2005) The following essay will be the analytical comparative study of the two Greeks theological perceptions on rhetoric and the way they developed the same.Socrates was living during the age of what classicist Eric Havelock has named â€Å"the crisis . . . in the history of human communication, when Greek orality transformed itself into Greek literacy† (Havelock, 1988, p. 1).Before this education was imparted orally and through poetic tradition going back hundreds of years and the Socrates opposed this form of education by proposing that education be made professional and should be imparted through dialectical examination of ideas and he was sentenced to death for the same.   (Havelock, 1988)Socrates developed his form of rhetoric from differences between the older tradition and the new literacy forms offered by the Greek alphabet. Greeks used different words to develop two different forms of communication-epos also known a s discourse that was both in written as well as in oral form.The public speaking and public discourse were so important in Ancient Athens that new form of rhetoric emerged and this gave birth to many professional teachers of rhetoric. These teachers were called as Sophists emerged from Sophos meaning wise and they were used to teach the art of rhetoric for their use in the courts, legislatures, political forums as well as in the political debates and philosophical dispositions.Among the Sophists, Protagoras was considered as the most influential among all, and his most important idea was â€Å"man is the measure of all things.† (Habib, 2005, p. 65) Protagoras laid his bases on the fact that each argument has two sides and there is equal rationale behind these two sides.He was accused of expediency in argument, as it could induce the people to think about the worst as best and best thoughts as worst. Another to enhance the concept rhetoric into the public sphere was Gorgias (4 85-380BC), whose disposition of rhetoric lay on the language of poets. He looked at the world as the world of opposites, contradictions and polarities, which could be reconciled by only the words of poetry. He viewed that rhetoric touched the soul and so poetry.Styli devices of poetry and sounds of music was rhetoric which could make the speech very interesting and soul touching, while the teachings of Isocrates were dependent on the political events and emphasized on the education as a form or rhetoric device.Like Socrates, he believed that education should impart moral values and emphasized on truth and virtue as the most important part of rhetoric and should include training of the mind and body as complementary form of activities. All in all their formation of the techniques of rhetoric emerged from the struggles out of the need of their political, educational and cultural causes.

Automobile and Cars Essay

The official definition of an automobile is â€Å"a passenger vehicle designed for operation on ordinary roads and typically having four wheels and a gasoline or diesel internal-combustion engine† (Merriam-Webster 51). There is no one person accredited for the invention of the automobile, but rather a collection of advancements that evolved into the modern-day automobile (Smith 12). Today, there are approximately 600 million passenger vehicles in existence worldwide, with numbers rapidly increasing in emerging economic â€Å"power countries†, such as China and India (Smith 23). A Flemish man named Ferdinand Verbiest introduced the first design for a self-propelled vehicle in 1672, in China, nearly one hundred years before the first internal combustion engine (Smith 25). From the late seventeenth century to the early nineteenth century, a series of vehicles, all propelled by steam, were constructed and demonstrated worldwide (Smith 34). The steam car was a superior machine in the nineteen hundreds (Smith 34). Steam cars were responsible for everyday travel, commercial transportation and even held land speed records (Smith36). It wasn’t until 1807 that the world’s first internal combustion engine was created, in France, by Nicephore Niepce (Smith 36). Another leader in the creation of the internal combustion engine was Francois Issac de Rivaz, who revolutionized the fuel that the engines ran on (Smith 36). Early automobiles powered by internal combustion engine ran on fuel made of powered and coal mixed with oil or a mixture of elements, such as hydrogen and oxygen (Smith 36). In 1824, and Englishman named Samuel Brown adapted the steam engine to burn gasoline and created the first gas vacuum engine (Smith 38). Sir Dougald Clerk, of Scotland, was accredited in 1876 for designing the first successful two-stroke engine (Smith39). In 1890, Wilhelm Mayback created the first four-cylinder, four-stroke engine (Smith39). Everything changed in 1885, when vehicle engineering took a sharp turn towards the future in regards to efficiency and affordability, thanks to the German inventor, Karl Benz (Smith 49). As the market for economical automobiles in the late nineteenth century began to grow, the need for industrial production was pressing. Benz patented the first four-stroke engine to be placed in his company’s production automobiles in 1888 (Smith 50). The first large-scale assembly production lines appeared in the early 1900s, many of which are still around today (Smith 24). Oldsmobile and Ford were two of the first companies to successfully mass-produce vehicles to meet the vast automotive market needs. American entrepreneur, Henry Ford, invented and improved the assembly line and installed the first conveyor belt system in his automobile manufacturing plant, based in Detroit, Michigan (Smith 95). Assembly lines reduced production costs by training workers to become experts with one specific part of the automobile or machinery, thus reducing production costs (Smith 97). Ford introduced the Model T in 1908, which could be assembled in an unprecedented ninety-three minutes. In the twentieth and twenty-first centuries, governments began to create and enforce automobile safety and environmental regulations (Smith 103). The World Forum for Harmonization of Vehicle Regulations is a working party of the United Nations Economic Commission for Europe (UNECE), the goal of this organization is to facilitate international trade by creating a uniform model of regulations for vehicle design (Corbett 67). The UNECE is also responsible for creating and enforcing regulations on vehicle safety among automotive manufacturers (Corbett 69). According to the World Health Organization (WHO), more than one million people are injured or fatally wounded on the world’s roads annually (Corbett 70). Some examples of vehicle regulations include seat belts, air bags and laminated windshields (Corbett 71). Seat belts limit the forward motion of the driver or passengers and absorb kinetic energy by stretching to retain movement if an accident occurs (Corbett 71). Air bags inflate to cushion to cushion the impact of the vehicle occupants and are placed in various locations in the vehicle’s interior, such as steering wheels, dash and doors (Corbett 71). Laminated windshields are designed to remain in one piece when impacted to prevent shattering, while maintaining visual clarity just after an accident has occurred, allowing the driver to safely redirect themselves from harm’s way (Corbett 71). There are also regulations for vehicle’ side windows and back windshield (Corbett 72). Windows and rear wind shields must be manufactured with tempered glass, which breaks into granules with minimally sharp edges, rather than splitting into jagged fragments as ordinary glass does (Corbett 72). Many new luxury features, such as paint color choices, differences in interior and upgraded designs and environmental features much as electric or hybrid engines in the twentieth century emerged on the market (Anderson and Anderson 167). The modern day automobile is a vehicle of evolutionary change and has transformed exponentially over the last several centuries. Today, the leading manufacturers of automobiles are Toyota (Japan), General Motors (USA), Volkswagen (Germany) and Ford (USA) (Corbett 22). These leading manufacturers all embody features and characteristics that make their product and branding unique and memorable, as well as abiding by worldwide government standards which include regulations of vehicle safety, environmental protection, energy efficiency and theft resistance (Corbett 13-16, 18). The evolution of motor vehicles from the seventeenth century to present-day is astounding. It would be reasonable to argue that the automobile is the single most evolved piece of modern machinery of all time. Motor vehicle usage has evolved over time, beginning with use for personal leisure and developed for commercial transportation, public transit and racing. The transformation of production and assembly, as well as the addition of customizable features mark the individualistic ideals of the twenty-first century. There no doubt, motor vehicles will continue to evolve throughout time with environmental needs at the forefront worldwide and the ever-growing necessity of increasing luxury among automobile owners. Works Cited Anderson, Curtis Darrel, and Judy Anderson. Electric and Hybrid Cars: A History. Chicago: McFarland, 2010. Print. Corbett, David. A History of Cars. New York: Gareth Stevens Publishers, 2005. Print. Merriam-Webster, Inc. , . Merriam-Webster’s Collegiate Dictionary. 11th. New York: Merriam-Webster, Inc. , 2003. Print. Smith, Kaelyn. A Brief History of Automobiles. New York: Webster’s Digital Services, 2011. Print.

A Description Of The Core Activities Within The Software...

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