Parliamentary Sovereignty in the UK in the Wake of Brexit

Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC Parliamentary Sovereignty in the UK in the Wake of Brexit Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC

Doubt in To The Lighthouse: Virginia Woolf’s Use of Symbolism and Tone

Virginia Woolf’s use of several literary devices, most especially tone and symbolism, can be seen in To The Lighthouse by dissecting important passages and analyzing how certain phrases connect with the work as a whole by enhancing the overall theme. The passage that Woolf best utilizes to convey both symbolism and tone can be found in her second chapter of the final section. Here she says, â€Å"He must have had his doubts about that table, she supposed; whether the table was a real table; whether it was worth the time he gave to it; whether he was able after all to find it. He had had doubt, she felt, or he would have asked less of people† (155). It is interesting to note that the theme of doubt and the subjectivity of feelings as they relate to material and nonmaterial objects continues throughout the text and the previous passage highlights this along with Woolf’s literary techniques by using the table as a symbol and the tone of introspection and guessing. This work is especially important and significant as a work of literature due to these important aspects used throughout. The previous passage should be understood in context with the events and the characters that are involved. Mr. Ramsey is a central figure of the piece, who serves as the host along with his wife of many guests to their summer house. His troubled marriage and his own doubts about his perception of how his life really is in contrast to how others may see it. His appraisal of the table, therefore, confuses one of his guests, Lily who is an aspiring artist or more specifically a painter. It is her voice in the passage that conveys the tone of the novel and that is one of subjectivity and the illusion that one person can understand another. Mr. Ramsey, on the other hand, helps to support the symbolism in this passage by simply using the table as a type of symbol to what constitutes what is important or beautiful in life as compared to what may be seen by others as unimportant or plain. The fact that the table is a solid object is also interesting in that this implies that even solid objects can be viewed differently by different people and it is not only relationships and all in life that is not static that is subject to deep thought and contemplation. While Lily contemplates that Mr. Ramsey has doubts about the reality of the table and believes that his doubts give way to his continual demands from others, it may be quite the opposite. Mr. Ramsey as the head of the household and the central figure and host of many dinner parties may see the table as the place where he is most comfortable and in charge of others, rather than in doubt of himself. Since the reader is only getting the point of view from Lily, Mr. Ramsey’s appraisal of the importance of or even the reality of the table is myopic. This ties in with the theme of doubt and the subjectivity of constructed reality that changes from individual to individual that permeates the passage, the chapter, and the novel as a whole. Lily, herself as an artist, presents her views from the eyes of an aesthetic and she has been influenced by this time by the late Mrs. Ramsey. But the philosophical ponderings of Mr. Ramsey among other events have given her doubts as to her ability to create anything of real meaning in her art and in her life. The final section of the work is the most sentimental and philosophical. By the time this passage has been uttered many deaths have occurred and the bridges that separate the remaining Ramseys and Lily are becoming more pronounced. The tone that Wolff uses has, to this point, been filled with confusion and foreshadowing and there is reason to believe that consonance might be found with the family when the remaining members, Mr. Ramsey and his son and daughter, finally do set out to see the lighthouse. There is some hope that with all the confusion and altered realities of the main characters at the close of the novel, that maybe all of them will see this lighthouse in the same way. For the entirety of the text, Woolf presents her characters as only guessing about the feelings and thoughts of others by how they view static objects, like the table in the passage. In the beginning of the book, the subject of the table comes up in terms of philosophy when Lily asks to have explained Mr. Ramsey’s thoughts on philosophy by his son Andrew. ‘Subject and object are the nature of reality’, Andrew had said. And when she said Heavens, she had no notion what that meant. ‘Think of a kitchen table then’, he told her, ‘when you’re not there’† (23). The fact that there are many missing people from the table towards the piece’s ending is what fashions the interactions between the characters to make meaning of their existence and to w eave all of this together with the subjective realities that each character has toward both the living and the deceased. This illustrates Woolf’s theme and her intentions for her audience to understand how the table is tied into the philosophy of Mr. Ramsey, who has become worn and saddened over the years, just as the table has been worn by time. As well, this illustrates Woolf’s use of the character Lily as a person, who is able to create objects that are new and subject to a redeeming action if her art is viewed by others to be important. As well, even if her art cannot save or redeem others in the end, she can by her own subjective reality, redeem herself in a deep and lasting fashion by discarding her doubts about herself. Certainly, Mr. Ramsey, Andrew and Cam all have doubts about the strength of their relationship and the value that is placed on visiting the lighthouse. What comes to be on this trip is not a singularity of vision between the Ramseys and Lily, but instead warmer feelings toward one another and the final realization that the only thing that can be shared is solitude. That dream of sharing, completing, of finding in solitude on the beach an answer, was then but a reflection in a mirror, and the mirror itself was but the surface glassiness which forms in quiescence when the nobler powers sleep beneath† (134). To be truly noble then, Wolff suggests that this singular vision without doubt or regret that each man or woman has is not something that can be shared, but instead it is to know that every one is alone is their vision for perfection within themselves and others. Everything else is subject to change or even the static objects like the table can be viewed differently, only we can know what we want and how casting off doubts imposed by others is what can essentially set us free. Woolf effectively utilizes the table as a symbol for the static in the world that can be seen as beautiful or ugly just as she uses objects like the mirror as a metaphor for solitude. The lighthouse, as well, is a beacon of light in the darkness, a darkness that is felt in loneliness. However, it is discovered by Lily that loneliness is noble when accepting it and discarding doubts about what is underneath the subjective surface of all things. Woolf’s introspective tone, used especially by Lily and the overall them of doubt and confusion in a world filled with change, both in the passing of time and even in the moments shared with others that may have different views illustrate how not even time changes the nature of the soul of men or women.

The Awful Secret of Persuasive Speech Template

The Awful Secret of Persuasive Speech Template Getting the Best Persuasive Speech Template Ladies and gentlemen the persuasive of life is easily the most incredible gift anybody may give. Men and women that are skilled and have mastered the art of earning different persuasive speech topics sound attractive and convincing as they can influence people with the direction they want. Most people have not mastered how to compose their speeches properly because they don't understand the way to use words well. The very best thing about speech is that anybody can make it. Possessing the capacity to offer compelling and persuasive speeches looks like a pure present. Tell your audience precisely what to do. You will receive exclusive texts, which will be concluded in time. You will receive exceptional texts, which will be concluded in time. You can't just offer a plain and easy start a speech once your purpose is to let them understand and believe every word you say. Among the crucial elements of a thriving persuasive speech doesn't be based on the outline you decide to follow. There are several different alternatives to commence a prosperous persuasive speech. There exist a number of different choices for beginning a prosperous persuasive speech. At the vital stage of your speech, you are going to provide a solution. Now you provide a solution. A template will remind you of the situations that you should concentrate on your speech. Once you have finished designing the template, it is very important to save it like a Word template so that you may use it later on. A speech template will permit you to sequence information effectively. It can prevent you from rambling. You may generate a similar selection of essay regardless of what type the quetion requires. As a consequence, it can be generally suggested to try to do a satisfactory study before deciding upon a particular assistance. In reality, you will be in a position to fulfill while using the author on line and chat about your research. In truth, it is possible to satisfy with all the author on line and concentrate on your research. Allocating a time limit for the key sections of your speech is a great way to keep on sample schedule. In excess of the period in your tutorial job, you're likely to be asked for to compose plenty of essays and papers on several subject areas, based on the education routine. Fast food needs to be taxed. Keeping to the speed limit may also help the surroundings. Normally, it's really simple to discover fully free essay, but there exists yet another dilemma for receiving the essay, which you definitely need to have. The principal idea of someone's complete essay will likely be your thesis assertion. The precise same is ideal for the best essay writers. Truthfully, careful planning is required to have a wonderful speech. New Questions About Persuasive Speech Template Above the duration of the tutorial occupation, you are going to be asked for to compose a great deal of essays and papers on several different subjects, based on the coaching routine. Just because of the fact the re are several alternate alternatives for what to put in writing about, additionally, you'll discover distinctive means of approaching an audio essay. Over the duration of your respective educational occupation, you may be asked for to compose a good deal of papers and essays on several subject areas, based on the teaching computer software. Over the period of a person's educational profession, you're going to be asked for to compose tons of papers and essays on numerous subject areas, based on the teaching system. Oral presentation topics must be dealt with properly to attain a desirable outcome. An essay may have a lot of intentions, although the simple composition of all form of essays will probably be similar. It can have lots of intentions, though the elementary construction of all form of essays will likely be very same. A good example essay will ensure it is feasible to analyze essay structure and outlines along with writing and reference stylethere are certain things which make a persuasive essay.

The Moral Code Of Ethics - 924 Words

Ethics is the study of what is right or what ought to be, depending upon the action of individuals. The reason why the individuals, plays a major part in ethics is because the principles of right and the moral quality of a course of action depends on them. As human being, we are moved mainly to action and not by moral judgments alone. People in society today use a set of principles that have been written, modified, abused and constantly changes throughout the years. In contrary, we must acknowledge both secular and religious followings, which have codes of ethics that they themselves supposed to follow. Coming from a Christian perspective, the Moral code of ethics that I go by is to walk by faith and not by sight. I believe and follow the divine command theory. Which assert that an action is morally good as long as God commands it. To be moral is to follow his commands only. I would also consider myself a rebel because some rules of society and other cultures does not line up with what God commands us to live by, so I rebel against them, with the intentions of doing what is right in God’s sight. However, I respect others culture, and I not do things to disrespect their beliefs. For example, I eat red meat, but if someone from another culture does not, I will not do it in front of that group of people. If their culture tells me to go against God, I will not allow myself to fail in his sight. Another can be an eye for an eye, in most culture when someone takes another life,Show MoreRelatedThe Moral Code Of Ethics924 Words   |  4 PagesThe moral code of ethics as healthcare p rofessionals is we have a responsibility and a moral code to our patients and the others we serve and they are: â€Å"Work to ensure the existence of a process to evaluate the quality of care or service rendered; to avoid practicing or facilitating discrimination and institute safeguards to prevent discriminatory organizational practices; work to ensure the existence of a process that will advise patients or others served of the rights, opportunities, responsibilitiesRead MoreCode Of Ethics And Moral Conduct2316 Words   |  10 PagesCode of Ethics and Moral Conduct By Tim Bowles OMM660 Business Ethics and Social Responsibility Instructor Prof. Andree Swanson June 27, 2015 Introduction Since morals and morality require conscious choices, man is the only animal who can be moral or immoral. 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