Krell v Henry and Herne Bay Stream v Hutton - Free Essay Example

Sample details Pages: 7 Words: 2098 Downloads: 9 Date added: 2017/06/26 Category Law Essay Type Argumentative essay Level High school Did you like this example? To what extent would you describe the reasoning in Krell v Henry [1903] 2KB 740 and Herne Bay Steam Boat Company v Hutton [1903] 2 KB 683 as either compatible or incompatible?Date authored: 23 rd July, 2014. On the 9th August 1902, the coronation of King Edward VII and Queen Alexandria took place. However, the festivities were originally planned for the 26th June of that year, having been postponed due to the King falling ill with an abdominal abscess. Don’t waste time! Our writers will create an original "Krell v Henry and Herne Bay Stream v Hutton" essay for you Create order This delay gave rise to a number of cases brought by parties who had contracted into arrangements whereby they could watch and participate in the (as originally scheduled) royal celebrations. Of these so-called ‘coronation cases, Krell v Henry [1] and Herne Bay Steamboat Co v Hutton [2] are the two that arguably led to the greatest refinement of the English law doctrine of frustration of contract. Both relied on the authority of Taylor v Caldwell [3] which clarified the position on contractual impossibility, a flavour of frustration which asserts that both parties to a contractual obligation may be freed from it if, by no fault of their own, performance of the contract was made impossible. Particularly, if the impossibility pertains to something which ‘strikes to the root of the contract, then both parties would be restored to their original position, as far as was possible. The assumed approach to frustration of contract involving contractual impossibilities was to examine whether or not the absence was implicitly central to the contract. Both of the aforementioned cases took this test – and the Taylor case as a whole – as a starting point, though the differing judgements present a prima facie incompatibility. However, it could be argued that the reasoning in both cases is largely compatible and logically consistent. Moreover, it could be argued that both cases read together have led to a greater cl arification of the doctrine of frustration which is evident from subsequent case law. Krell and Herne Bay are distinguishable in terms of both the material facts and the decision reached. Krell concerned a defendant who rented a flat from which he intended to watch the coronation procession. The contract was held to be frustrated, even though he could still rent and occupy the flat, as the viewing of the procession (now impossible due to its rescheduling) was deemed to be the foundation of the contract. Even though the coronation was not explicitly mentioned during the pre-contractual negotiations, the court concluded that this intent was both implicit and integral. In Herne Bay Steamboat Co v Hutton the defendant contracted to hire a steamship to watch the royal naval review and to take a â€Å"days cruise around the fleet†. This contract was not held to be frustrated; even though the naval review was no longer possible, the defendant could still take part in t he cruise regardless. We see, therefore, a fundamental irreconcilability in the application of the ‘implied term test established in Taylor; in both cases the parties entered into their respective contracts with the royal festivities being the implicit reason for the contract. That there is another element – that of a general cruise around the fleet – in Herne Bay should be irrelevant; ostensibly the court had taken a less absolute view of the hiring parties intent in making their judgement. Criticism has particularly focused on Krell – Roberts (2003, para. 30.) paints the ruling in Mr Henrys favour as being fundamentally at odds with the common law principle of sanctity of contract. In Herne Bay, Stirling J accepted the logic of Taylor, but said the fact that the parties could still visit the fleet denied the possibility of frustration. He opined that the royal naval review was descriptive as to the nature of the trip, but not fully indicative of what was contracted for. In essence, the contract was limited, but not utterly diminished; that is, the cruise itself could still, and would still, go ahead as planned, merely without the coronation element. Therefore, the cases demonstrate judicial analysis of Taylor yet a reluctance to adhere to its core tenets; in Herne Bay there was held to be no frustration even in the case of a unique subject matter, lost due to impossibility, which stood as an overt reason for forming the contract. The treatment in this case becomes more similar to non-frustratory contract cases where a pursuer sues over a ‘loss of enjoyment, such as in Jarvis v Swan Tours[4]. I would argue, however, that instead of an incompatibility – the extent to which either case followed the Taylor reasoning – these decisions instead indicate a move to the more elegant test discussed in the later case of Davis Contractors v Fareham Urban District Council [5]. In this case, Lord Radcliff e reasoned that frustration would be possible when â€Å"such a change [has occurred] in the significance of the obligation that the thing undertaken would, if performed, be a different thing from that contracted for.† This test asserts that if the supervening act radically changes the subject matter of the contract then it will be frustration. If Krell and Herne Bay indeed contain an early iteration of the test in Davis, then they are compatible within this framework. To elaborate, in Herne Bay the royal presence may have formed part of the pre-contractual consensus; however, the contract would not be radically different after the change of circumstances as Mr Hutton could still make a profit from taking passengers on a pleasant tour around the fleet regardless of the timing of the coronation. Mr Henrys use of the flat, conversely, would be radically different as he would be obliged to make payment for a flat he has no use for, watching the coronation being the sole purpose of the rental agreement. Krell, therefore, is not merely distinguishable and of limited scope of application as opined by Koffman and Macdonald (2010. p.511), but just as thematically consistent with the ‘radical difference test as Herne Bay. Continuing to suppose that Krell and Herne Bay share an early adoption of the â€Å"radical difference† test, we may examine two cases which share the echoes of their logical reasoning; Nickoll and Knight v Ashton Eldridge Co [6] and Tsakrioglou Co Ltd v Noblee Thorl GmbH [7] . Nickoll concerned a stranded ship which was unable to deliver its cargo. As in Krell, the impossibility of performance is clearly radically different to what both parties intended. In Tsakrioglou, another merchant shipping case, the ship in question was unable to deliver its cargo through the Suez canal – as originally agreed by both parties – due to political reasons. The court held that taking the alternative Cape of Africa route was not frustratory. This case, as in Herne Bay, may have fallen on a bare interpretation of Taylor, but the court maintained that even limited performance should be upheld. It also suggests a high bar for situations in which courts will agree that frustration has taken place. This high bar further supports the idea that Krell and Herne Bay share compatible reasoning; the courts have been keen to prevent frustration from being an easy escape from a contract for fickle parties. Treitel (2004, para 7.14) points out that the conti nuation of any part of the contract apart from something trivial makes frustration unlikely.In Blackburn Bobbin Co v Allen [8] the outbreak of war was held not to be frustratory, even given concerns by the merchant shipping company that the goods would be destroyed due to the predations of the Imperial German navy. This high threshold – which exists to prevent buyers evading a minor disappointment, or vendors a more difficult method of supply – is evident in Krell and Herne Bay (with regards the former, Morgan (2013, p120) suggests the high threshold has been reached as Mr Henry lacked an obligation to reschedule given that the King may not have survived his appendix surgery). As well as both cases being decided â€Å"correctly† against the high threshold for successful frustration, both demonstrate a common judicial reluctance to infer too much of the mental thought processes of the parties. Brownsword (1993, p246-247) puts forward a key distinction; Mr Krell was treated as a consumer he had a very specific intent in mind, an assumption the court had little difficulty in basing their judgement upon. In Herne Bay, however, the Court of Appeal was unwilling to infer such a clear purpose. Mr Hutton intended to hire the steamship so that he could in turn hire the use of it to paying guests. Stirling J asserted that the â€Å"risk fell on the defendant whose venture the taking of passengers was†. This suggests a shared reasoning – the judges are more likely to be able to establish the root of a contract where it concerns a disappointed consumer rather than assess the nebulous interests of remote third parties in the more commercial situation seen in Herne Bay. Alternatively, it can be said that compatibility simply is not relevant. As indicated above, it can be argued that the evolution from Taylor to the test in Davis is a move towards a fairer system. However, Lord Wilberforce in National Carriers v Panalpi na [9] was reluctant to assert the supremacy of either test. He suggested they overlapped considerably and that the one used is the one â€Å"most appropriate to the particular contract under consideration†, that is, the tests should be used on a case by case basis depending on the specifics of that particular situation. Furmiston et al (2012, p.722) draws an analogy to the standard of the reasonable man, suggesting the organic approach taken in these cases was correct. To conclude, the reasoning in both the cases examined is compatible. The judges Vaughan Williams J, Stirling J and Romer J sat on both cases, and it cannot reasonably be inferred that they intended to create clarification on the precedent laid down in Taylor without ensuring the cases can be read in concert with one another. Indeed, the words of the judges suggest that they had precedential consistency very much aforethought; Vaughan Williams J stated that all cases of this type must be decided on their own merits, indicating a preference for the more organic approach later seen in Davis. He even went on to evoke a strong analogy akin to the facts of Herne Bay when making his judgement in Krell; that of someone who has hired a taxi to take him to the Epsom Derby. Even in the event of the cancellation of the Derby, the contract to convey the hirer to Epsom still exists. As previously stated, both cases stand under the weight of the later approach taken towards frustration in cases such as Davis, that of looking at whether or not the contract is so radically different as to make freeing the parties from it the only fair and reasonable course of action. Additionally, the cases clearly delineate situations in which a court will be willing to apply the doctrine of frustration – the court plainly saw the contract was robbed of its commercial value in Krell yet recognised the situation in Herne Bay was still commercially viable; as Lord Roskill in Pioneer Shipping v BTP Tioxide [10] remarked, the doctrine of frustration was â€Å"not lightly to be invoked to relieve contracting parties of the normal consequences of imprudent commercial bargains†. The cases clearly demonstrate how this doctrine may be correctly applied. As the cases fit so comfortably within the radical difference test and the reasoning applied to each of them can be seen in following case law, we can conclude that they are compatible. Bibliography References Furmston M. P. (2012) Cheshire, Fifoot Furmstons Law of Contract (16th edition, Oxford University Press) Koffman L. and Macdonald E. (2010) The Law of Contract (7th edition, Oxford University Press) Treitel, G. (2004) Frustration and Force Majeure (2nd edition, Sweet Maxwell) Brownsword, R. (1993) ‘Towards a rational law of contract, in Willhelmson, T. (ed), Perspectives of Critical Contract Law (Aldershot: Dartmouth) Morgan, J. (2014) Contract Law Minimalism: A Formalist Restatement of Commercial Contract Law (1st edition, Cambridge University Press) Roberts, T. (2003) ‘Commercial Impossibility and Frustration of Purpose: A Critical Analysis, 16 Can. J. L. Juris 129 Cases Blackburn Bobbin Co Ltd v Allen (T.W) Sons Ltd [1918] 2 KB 467 Davis Contractors Ltd v Fareham Urban District Council [1956] UKHL 3 Herne Bay Steamboat Co v Hutton [1903] 2 KB 683 Jarvis v Swans Tours Ltd [1972] EWCA Civ 8 Krell v Henry [1903] 2 KB 740 National Carriers v Panalpina [1981] AC 675 Nicholl and Knight v Ashton , Eldridge Co [1901] 2 KB 126 Pioneer Shipping Ltd v BTP Tioxide Ltd [1982] AC 724 Taylor v Caldwell [1863] EWHC QB J1 Tsakiroglou Co Ltd v Noblee Thorl GmbH [1962] AC 93 Internet Resources www.lexisnexis.co.uk legalresearch.westlaw.co.uk [1] [1903] 2 KB 740 [2] [1903] 2 KB 683 [3] [1863] EWHC QB J1 [4] [1972] EWCA Civ 8 [5] [1956] UKHL 3 [6] [1901] 2 KB 126 [7] [1962] AC 93 [8] [1918] 2 KB 467 [9] [1981] AC 675 [10] [1982] AC 724

Supply Chain Management Practice, Theory, And Future...

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Samla’s Personal Statement Free Essays

â€Å"The vision that you glorify in your mind, the ideal that you enthrone in your heart – this you will build your life by, and this you will become. † These very powerful words, written by James Allen, are a perfect description of how I have accomplished many of my goals. My main objective is to obtain a full time position with a public accounting firm to render professional services in the field of auditing. We will write a custom essay sample on Samla’s Personal Statement or any similar topic only for you Order Now Some years ago, a former student of University of California, Irvin brought my attention to the field of auditing. I took the initiative to find out more about this career. After extensive research on the nature of the work, training and advancements, I felt this is something I could really enjoy doing for the rest of my life. I began exploring the different fields that are related to auditing programs offered and making campus visits. After several visits and consults I was attracted to the CSUF because the school allows new students to involve themselves in independent research, requiring initiative, self-motivation and a wide range of skills within the first few months and also allow students to go out for industrial practical exposure at one point or the other on a yearly basis throughout the duration of the degree. Since many of us, at one point or the other in our life, we need a professional care and assessment as regards our finance management be it an organization or the money we save or trade with or in any other capacity . So, I see this as an opportunity and it brings me great pleasure thinking about the effect I could have on the populace at large. Therefore, I have always been aware of equipping myself with solid foundations in IT and supporting knowledge in Business aspect in order to fulfill the challenging requirements of future working environment. Besides professional regular education, I have attended several trainings and extra courses instantly when I had chances and time. These include Software development, Networking, and Business development (Please refer to my resume). Academic Background and skills I attended Orange Coast College, Costa Mesa with Honors List and I major in Accounting where I got a befitting Orange Coast scholarship. I also attended Government Commercial college,Karachi,Pakistan where I had Bachelor of Commerce and I major in Accounting too. (Jan 2003-Dec 2004). Working experience My working experience dated back to early January 2004 when I was offered the post of an accountant at the Zaitoon M. A. Shakoor Brokerage Firm Karachi Stock Exchange, Karachi, and Pakistan. I was exposed to the various dynamics of stock market. 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Value Chain and REA Analysis

Question: Discuss about the Value Chain and REA Analysis. Answer: Introduction Due to growing complexities and future challenges in the health system implementation projects, it is essential for the Queensland Health System to manage the implementation, stabilization, and maintenance of the information system project implementation in order to ensure the smooth running of the business operations. This assessment will describe the factors that contributed to the failure of payroll system implementation project at the Queensland Healthcare System(Bischoff, 2011). This assessment will also propose several recommendations to identify deficiencies in the system analysis for ensuring the better implementation of the IS projects at Queensland Health System. Objective- The objective of this report is to identify and analyze the factors that contributed to the disastrous information system implementation projects at the Queensland Health System. This report is aimed at understanding the applications related to the project implementation failure at the Queensland health system on national and state legislations as well as industrial level. Factors contributing to the failure of the Queensland health payroll system implementation The Queensland Health Payroll System implementation project failure is one of the largest IS failures in the Southern Hemisphere that highlighted the significance of systematic project failure. This project failure accounted for costing to $ 1.25 Billion ASD ($ 245 million AUD for fixing the system failure problem and $1000 Million dollars for maintaining and operating the system). This IS project failure was 300% over budget and 18 months behind schedule. This project failure estimated costs $1.25 billion AUD in implementation, stabilization and maintenance of the system(ThiteSandhu, 2014). There were several reasons that contributed to the failure of the payroll system implementation at the Queensland Health System which are following as:- Lack of planning and failure to keep the robust tendering process- The poor project planning and failure of the project team members to put in place the robust tendering process contributed to the failure of the Queensland health system implementation project. Weak governance structure and Lack of clear roles, duties and responsibilities- The poor governance of the Queensland Health Implementation caused for the unclear and confused system implementation projects. It also created confusion in the roles, responsibilities, duties, authorities, and accountability of the several parties involved in the project implementation process. Lack of stakeholders participation and engagement in the companys decisions- The lack of all stakeholders engagement in the company meetings and decision-making process was another reason contributing to the failure of the Queensland Health Payroll System. Lack of risk management and poor contingency plan- The pre-implementation process and system testing failed to identify the risks that contributed to the Queensland IS implementation project failure. There was no contingency planning and monitoring process for managing risks that resulted into the over project budget costs for the project implementation activities(Horngren, Harrison, Oliver, Best, Fraser, Tan Willet, 2013). Lack of communication and training and poor management control- This was the root cause for the failure of the IS implementation project at the Queensland Health system. There was little communication or less conversations among the project team members that resulted into failure of the implementation of IS projects at Queensland Health System. Failure to deal up with the complex processes required for the implementation of a new system The management and project team members failed to deliver optimum project implementation results because of the failure of the project team members to clean up the complex processes for the successful implementation of the new payroll system At the Queensland Health System. Poor team management structures- The poorly designed team management structure was one of the key factors contributing to the failure of the Queensland payroll implementation projects greatly. The project team members were not assigned the projects activities as per their skills, knowledge, and specialization(Mancini, Vaassen, Dameri, 2013). Lack of commitment- The lack of commitment and self-responsibility among the staff members including doctors, nurses, managers, and other employees was another reason caused for the failure of payroll implementation project at the Queensland Health System. Lack of diligence on behalf of the state government officials- The unwarranted urgency and lack of diligence of the state government health officials caused for the poor decision making that resulted into failure of payroll implementation project at the Queensland Health system(Hall, 2012). Lack of accountability of the payment of staff members- This factor contributed to the failure of the IS implementation projects resulting from the lack of accountability among the employees of the Queensland Health System including nurses, doctors, and other staff members. Due to indefinite payment structure, the Queensland Health System had to face the grievances and conflicts of the staff members. Inaccurate estimation of the project scope and complexities- The Queensland Health Payroll System was failed because it was complex comprising of multiple employment awards, large workforce, and various project agreements that resulted into the replacement of QLD payroll system by the new payroll system(GelinasDull, 2009). Environmental and technological project drivers- This was another factor that contributed to the failure of the Queensland IS implementation projects. Classification of the factors into the phases of the first step of SDLC approach The factors responsible for the failure of the Queensland Health payroll system implementation project are classified into the relevant phases of the first step of the System Development Lifecycle Approach including System planning, Analysis, Design, Implementation and Maintenance/Review. These factors are following identified as per different phases of the System development Life Cycle approach:- Planning- This phase includes the factors that contributed to the failure of the payroll system implementation, such as the lack of planning and failure to keep the robust tendering process, early establishment of conditions of stakeholders participation and expectation management, lack of contingency planning, employment agreements, and review shared services central approach to centralization and flexibility. Analysis- This phase includes the factors, like weak governance structure, unclear roles, duties and responsibilities, lack of alignment of people, process and technology,environmental and technological project drivers, periodic review of the business needs in cope with the changing environment(Romney, Steinbart, Mula, McNamara Tonkin, 2012). Design- This phase includes the factors, such as failure to clean up the complex processes required for the implementation of a new system, lack of risk identification and management, poor system design and lack of supervision, lack of new system requirements, lack of commitment and self-responsibility, and lack of interest of the management to deliver the best system design solution. Implementation- This phase includes the factors, such as comprehensive change management, external environment and technological forces, lack of professionalized training and education, mature and inconsistent system testing, impact of system management changes, inaccurate estimation of the project scope and complexities, and lack of accountability of the payment of staff members(Eden Sedera, 2014). Maintenance/Review- This phase of SDLC approach includes ongoing project management, reviewing the system performance, ongoing stakeholders engagement, and lack of periodic planning, review and control of high risk projects. Recommendations to overcome the deficiencies for the future implementation of IS projects The Queensland health implementation project failure is one of the largest IS failures in Australia that requires a series of recommendations to overcome the deficiencies for the future implementation of the projects at the firm. The following recommendation could be applied to improve the information system implementation projects at the Queensland healthcare system:- Greater Communication- Communication is an important project management aspect that should be taken into account by the management of the Queensland Health System to ensure the successful implementation of the future IS projects. It is recommended for the senior management of the Queensland Health System to promote greater communication among the project team members for ensuring the successful completion of the future IS projects. The inter-organizational communication is imperative to the IS project management team to minimize the user-resistance barriers. An effective communication among the project management team members will assist to resolve the conflicts and disputes of the organizational members by protecting their interests. Along with this, the greater communication will bring them together to work on the projects for removing the deficiencies or loopholes in the IS projects by sharing their experiences, values and knowledge with each other(Considine, Parkes, OlesenBlount, 2016). For this, the communication tools, such as team viewer, Skype, social media (Facebook, Twitter, Pinterest, Instagram, LinkedIn, and Google+), e-mails and intranets can be used to enhance the level of communication among the project team members at the organization. Improved data quality and system testing- It is important for the Queensland Health System to improve the quality of data and system tests for attaining the better IS project implementation results at the firm. The system testing will analyze the effectiveness and efficiency of the organizational IT system of the Queensland Health system to remove the problems of discrepancies, casual labors, overtime claims, inadequate and unstructured payroll system. Along with this, the system testing will improve the data quality by performing the data conversion security, integrity and quality management issues. The integrated computerized system can also be used to improve the quality of data(Cram101 Textbooks Reviews, 2016). Digital transformation of health services- The Queensland Senates digital transformation of the healthcare services will assist to enhance the knowledge and experiences of the project team members, clinicians, and digital health experts by using the digital technology. The digital transformation will also improve the digital hospital information infrastructure of the Queensland Healthcare System by performing all activities electronically(Gelinas, Dull Wheeler, 2014). The digital transformation of the health will resolve the payroll system implementation problems by supporting the quality of healthcare, consumer health, quality measurement and improvement, public accountability and clinical education and health researches. System Development Life Cycle- This approach is also known as application development life cycle that can be used by the project management team of the Queensland Health System to implement the IS projects successfully by overcoming the loopholes and shortcomings in the system design. This approach uses information systems, system engineering and software engineering to implement the process for planning, designing, testing and deploying an information system. This approach will be supportive to identify the deficiencies in the existing system and thereby defining the new system requirements after analyzing the environmental forces and technological changes. Clinician engagement- This is important for the project planning, evaluation, and delivery improvement of the healthcare services at the Queensland Health system for achieving the desired IT project results and healthcareefficiency(Gable, 2008). For this, the Queensland Clinical senate can develop a position statement on the clinician engagement to assist the healthcare, hospital and medicare services in order to measure the efficiency of the clinician engagement against the clinical senate statement. Advance care planning- The advance care planning can enhance the effectiveness of the Queensland healthcare services by improving the quality of end of healthcare for the patients. The Queensland Health System should focus on development and implementation of the standardized practices advance care planning documentation for providing the quality of primary care, hospital services, and medicare services. Clinical Teaching and training- The clinical learningand training is an important aspect that the Queensland Health System should be focused on for improving the quality of health system at the organization(Cooper, FunnellLee, 2012). For this, the Queensland Health System should focus on budget allocation, the learner-teacher experience, information governance, professionalized training, and team-based simulation training to improve the effectiveness of the healthcare system implementation projects at the firm. Conclusion From the above studies and analysis, it can be concluded that the Queensland payroll system implementation failure was one of the largest information system project implementation failures in the southern hemisphere that was caused from a range of factors examined by the Royal CommissionAustralia (healthcare system enquiry judiciary of Australia). Several recommendations were also suggested by the Royal Commission that can be applied to the Queensland healthcare system in order to overcome deficiencies in the IS implementation projects. References Bischoff, L. A. (2011).Porter's Value Chain and the REA Analysis as an Accounting Information System. Australia: Grin Verlag. 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