Essay Ppan Tahun 2011 free essay sample

ASSIGNMENTS My biggest achievement was when I was chosen by the Senior High School to join the mathematics Olympiad East Java in Wijaya Kusuma University Surabaya. I really did not suppose this matter because for my studying process not including the clever student, but because of the curious feeling that was so big about the lesson that was explained so as I always active asked. And during the Olympics I was very grateful because of could enter 15 big from hundreds of students, this was the achievement that will not be forgotten while I studied in the Senior High School until now. Whereas my biggest failure was when I decided to leave the place study the Surabaya state university. All my friends in university wanted to play by going to class and not serious studied so as this matter that made me to be not comfortable to go to class and decide to go out from there. We will write a custom essay sample on Essay Ppan Tahun 2011 or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page When I took this decision my parents really did not support and angry, because I entered the university with great difficulty but went out so fast. At the time I really was regret because my family not there is one that is supportive with my decision. However after that my best friend came and inspired me and said to continue to remain although not there are those that agreed but if you were convinced did, this matter that made me rise and begin explained to the family about my reason left this university. After several old I the vacuum study finally in this year I began the lecture in PCP ITS took the route system the administrator, because since long ago I had been attracted by information technology. My plan for the next five years is get the degree of the scholar technique. Afterwards I will help children to study about the function of the internet and the computer for the period now and the future. Because at this time the child at the Primary School often do homework by using the computer and the internet to search the task. In the beginning they won’t give the explanation ate increasingly old they will increasingly the difficulty for the further lesson. My motivation in joining this program was I want to look for the new experience that had never been carried out by me before. Although now already many networks social like twitter, Facebook, and me2day as means to interact with the outside world but if directly came to his country directly according to me that is will be better, because we can interact and know about the customs and traditions as well as the outside country culture that must be different from Indonesia. According to me interpret the platform GET INVOLVED! Indonesian youth for global issue were some interpret that was exact because if beginning with early the younger generation must be explained about their global issue will begin to think how to understand the situation and the condition in the world So as at the time of mature they have been used to it globally issue. They will understand the situation easily and could give the suggestion about global issue because they have known global issue since long before and global issue could be resolved together without the existence of the violence The problem in Indonesia that most was paid attention to me that is many Indonesian artists who use drugs. My opinion necessarily they realize that they become the crowds model, but they even show the bad side a person public figure. If they realize about their responsibility as my artist the feeling of the artist in Indonesia more will advance than now. Because of many artists from outside like Boy band from Korean Super Junior they become some icon hallyu wave owing to their hard work up till now so as all the cracks in this world know them. Can not be ignored because the development blessing of their time was famous the blessing from the internet also for example from you tube that many videos performers they. After I completed this program I hope can be useful for the community. And because I have been to the member and the management of Karang Taruna ( youth ) in the environment around me, I can give information that I can for the program to increase motivate children in my environment. This was done because of many of my neighbors that still the primary school, Junior High School and the Senior High School not all that had the motivation that was high in studying so as they often escape the school and that worst they leave the school. If they aware of the importance of their education of getting the profit that several fold. They can increase knowledge in the school, can help the environment around from knowledge that we can, and that is most important our parents will definitely be proud of what we can, get everyone in the world want to develop and be useful for the crowd.

Free Essays on My School

my definition in Nieto would be, â€Å"Multicultural education is reduced to making exotic masks, eating ethnic foods, ..Etc† (Nieto, 325), â€Å"students were unaware of what multicultural education might be if it were approached in a comprehensive manner† (Nieto, 326). By approaching multicultural education in a more comprehensive manner Nieto meant making ethnicity a class and part of mandatory curriculum. Studying ethnicity will make us more tolerable of other cultures. An example from my elementary school is an example from my 8th grade year. The teacher assigned us to each do reports on different cultures. With the report bring in food from that culture and whatever else you deem necessary. Recently this activity at the school was condemned by the school administration because they wanted a more involved curriculum in order to show that the school was moving with the times. They instituted a class that most grades are receiving now, that consist of a chopp ed down ethnic studies class for grades 5-8. This would bring the school I think up to the level of Respect. In order to move up to the next level of multicultural education I think the school would have to include all grades and not just a centered class for diversity as it is now but include the class in all aspects of schooling. A more specific example would be to take the diversity cla... Free Essays on My School Free Essays on My School The school I am going to focus on is my private school back home in Huron, Ohio, St. Peters’ Catholic elementary. It was a small catholic school but large for a town of 6,000 people. I think the two most important characteristics are Important for all students and Antiracist/Antidiscriminatory. Important for all students I would define as curriculum that everyone should be able to have in their schools. When reading the words, important for all students, I would say that means giving all students mandatory diversity included in the general curriculum. An example that best words my definition in Nieto would be, â€Å"Multicultural education is reduced to making exotic masks, eating ethnic foods, ..Etc† (Nieto, 325), â€Å"students were unaware of what multicultural education might be if it were approached in a comprehensive manner† (Nieto, 326). By approaching multicultural education in a more comprehensive manner Nieto meant making ethnicity a class and part of mandatory curriculum. Studying ethnicity will make us more tolerable of other cultures. An example from my elementary school is an example from my 8th grade year. The teacher assigned us to each do reports on different cultures. With the report bring in food from that culture and whatever else you deem necessary. Recently this activity at the school was condemned by the school administration because they wanted a more involved curriculum in order to show that the school was moving with the times. They instituted a class that most grades are receiving now, that consist of a chopped down ethnic studies class for grades 5-8. This would bring the school I think up to the level of Respect. In order to move up to the next level of multicultural education I think the school would have to include all grades and not just a centered class for diversity as it is now but include the class in all aspects of schooling. A more specific example would be to take the diversity cla...

Write a critique about Cinderella A story of Sibling Rivalry and Assignment

Write a critique about Cinderella A story of Sibling Rivalry and Oedipal Confilcts By Bruno Bettelheim - Assignment Example This is created from the conscious part of our brains. According to Hentz (2002) the unconscious part of our brains has the ability to dig deeper into the story and relate to another interpretation. This is the same in a child’s brain where is it possible for a child to create both conscious and unconscious interpretation of a story. The Cinderella story helps children relate with their difficulties in life. In the essay Bruno Bettelheim goes deeper trying to explain how sibling rivalry and the oedipal stage in children contribute to their difficulties in life. The author argues that children relate greatly to the Cinderella story when they are faced with the difficulty of sibling rivalry. They tend to hope that they will get something great from the tribulations just as Cinderella did. While at the oedipal stage children do not have the ability to differentiate different emotions. They cannot differentiate between anger, guilt, jealousy, parental criticism, worthlessness and rejection (Hentz, 2002). However, with fairy tales like the Cinderella children can very appropriately relate to their emotions. The fairy tales provides children with an outlet for their thoughts. And it is for this reason that parents and teachers try to relate life to children by using and applying fairy tales in the real life. Just like the Cinderella story children cannot wait for their freedom from their parents. They yearn for the day that they will be independent from their parents. The essay by Bettelheim has points which I liked and other worthy of criticism. The author downplayed the original purpose of a fairy tale. When reading a fairy tale, the whole idea is entertainment (Hentz, 2002). Fairy tales as the most beautiful stories a child can relate to without relating them to their difficulties in life. The author takes beauty from them as he argues that children should find more than

International HR Management in Australia and India Case Study

International HR Management in Australia and India - Case Study Example Startup IT Company, which has recently established a subsidiary in India (New Delhi), has various options that can be followed to attract candidates for the different job position both internally and externally. Accordingly, the company is looking forward to attract candidates for different job positions listed as five senior executive, fifteen line managers, supervisors for two call centers, thirty staffs divided in to two groups for dealing with customers and suppliers and fifty assembled line workers. It is to be noted that the senior managers will be recruited from Australia while other professionals can be recruited from India. Accordingly, each job position has specified job description which shall facilitate in executing the recruitment and selection process more effectively. In order to ensure that right person is placed for the right job position, the company has the two major options of internal and external workforce for imbibing considerable talent within the organization . Additionally, internal and external recruitment processes shall provide the company with the opportunity to meet its needs for recruiting and selecting potential talents inconsistent with the job description and specification. One of the most suitable options available with Startup IT Company for targeting potential candidates can be related with its internal recruitment prospects facilitated with skilled labor force. It is worth mentioning that targeting candidates internally poses significant benefits. to the company. Responsively, the company will be able to save considerable amount of finance if the company follows internal recruiting. In addition to finance, the company will also be able to save considerable amount of time generating greater employee satisfaction and morale (Briggs, 2007). Some of the basic tools that the company can use for targeting candidates have been illustrated as follows. Promotions and Transfer It is worth mentioning that promotion and transfer is a vital tool for recruiting candidates internally. Contextually, Startup IT Company can take promotion and transfer as an important tool for recruiting candidates internally. The company can promote managers as senior executive on the basis of their capability and the past performances. It can also have the option to transfer managers from hone country i.e. Australia to India in order to assign them with the task of a senior executive (Ferner & et. al., 2005). Employee Referrals Employee referrals can be regarded as another important tool available to Startup IT Company to fill the vacant positions. The organization can recruit staffs on the basis of

The Cause And Effects Of Consumerism Cultural Studies Essay

The Cause And Effects Of Consumerism Cultural Studies Essay Consumerism is the term used to describe the effects of equating personal happiness with purchasing material possessions and consumption. Today we live in a consumer culture obsessed world. Consumption encompasses our everyday lives and structures our everyday agendas. The values, meanings and costs of what we consume have become an increasing important part of our social and personal experiences. The main factor enforcing our actions in this way is the news media. The news media is filled with information about consumption- not only in the form of advertising but also as news about businesses, lifestyles and economic indicators. However none of this tells us how we came about as a culture that associates freedom with the freedom of consuming anything of our choice and as a means of self-fulfillment. All cultures have found meaning in material goods. Objects resemble a social status or go further than that and have an emotional attachment with ones self. Goods are not only consumed for there material characteristics, but even more for what they symbolize- there meanings, associations and there involvement in our self image. Consumption is not simply the acquiring of products predestined meanings. Instead, it should be seen as a form of social consumer culture. While consumption is an act, consumer culture is a way of life. It is quite likely that never before in history has consumption become one of the central values of a culture. In modern society one learns merely to consume, and tasteful or appropriate consumption is only one of the numerous choices. It is this focus on consumption as a central worth that makes us a consumer culture. Consumption no longer seems to reflect our cultural values; it has itself become a cultural value. It has entered into the warp and turmoil of this fabric we call modern life. Every public space, every occasion for public gathering, every creative expression is seen as an opportunity to encourage more consumption. To understand how we have become this consumer crazy culture it is important to understand the humble beginnings of this crazy fixation. Before the industrial revolution of the eighteenth century, what people consumed was, either goods mad by family members or a person the consumer has a personal relation with. In early Europe the form consumerism took place in the weekly markets and seasonal fairs. The historical pattern in America was somewhat different. Unlike in Europe, where markets and fairs preceded the development of shops, in America shops emerged as the customary way of buying and selling in its early colonial period. It was not until the eighteenth century that markets and fairs became popular in the United States. Fashion is one of the key elements that fuel consumerism. Fashion not only includes clothing, but also any object where there is a concern for what is different, new and improved and which allows us to express our individuality. Fashion is so central to modern day consumption that it is difficult to imagine a culture in which it is not a major force. People throughout time have always been interested in the beautiful or in signs of status and in the pursuit of anything that brings them pleasure or happiness. It was during the last quarter of the sixteenth century in England that consumption first took off amongst the European nobility. This powered to two important developments. First, Queen Elizabeth the first used the dramatic spectacle of fashion as a display of government power. Second, she forced social competition among the nobility by removing them from their locality where they were clearly superior and forcing them to attend the London court where they had to compete with equals. Previously consumption had always been a family matter and what benefited the family the most. But now Elizabethan noblemen began to spend less on their families and more on themselves to further show there class and status. Josiah Wedgewood was one of the pioneers in the consumption phase. He had this new understanding of fashion and the market place. Wedgewood was a manufacturer and retailer of pottery in the eighteenth century. He was the first to recognize that if the rich and elite could be induced to adopt fashions, the other classes would follow soon. There are only certain societies where it is possible for a fashion to spread to the higher class to the lower class. Fashion has to be affordable for those in the lower class and the classes must be close enough with some fluidity between them that those in the lower class could imagine themselves owing what those in the upper class have. In England during this period the lower class was eager to possess whatever the upper class deemed fashionable. Wedgewood understood the immense financial potential of such a social situation and learnt how he could control it. His fashion tool was pottery. Wedgewood learned to closely observe what the upper class was buying in order to predict what direction the lower class consumption habits would follow through. Another factor adding to the consumer culture is the portrayal of this culture. In the United States consumption spurred as a symbol for rebellion rather than a symbol a homogeneous conformity. Schutte and Ciarlante describe Coca cola, Levis and Marlboro as symbols of individualism and freedom. Three phrases from Stuart and Elizabeth Ewens Channels of Desire (1982) which they see as indicative of the recent tendencies within consumer culture describe it best. Today there is no fashion: there are only fashions. No rules, only choices. Everyone can be anyone. This suggests there is a war against uniformity, a surplus of difference which results in a loss of meaning. The repercussion is that we are moving towards a society without fixed status groups in which the adoption of styles of life which are fixed to specific groups have been surpassed. We have been encouraged to buy in order to establish our individuality in a mass-produced culture. To express our disgust with consumption by more consumption, to purchase the latest improved traditions. Now people are encouraged to buy to convey their rejection of homogenized lifestyles. This anti-consumption attitude only fuels more consumption. Years ago, many people imagined that life would be idyllic in the 21st century. Technology would have cured most human short-comings, and there would be abundance of resources available for all. Population growth and over consumption underlie many of the invasive environmental and social concerns that humans face today. Over consumption of our natural resource base is jeopardizing ecosystems throughout the world. Wealthy nations like the US amount to 20 percent of the worlds population, yet they use more than 70 percent of the earths resources and generate an even higher volume of wastes. Some of these wastes are released into the atmosphere, rivers and oceans, others are land filled or incinerated, a small part is recycled. The standard notion of economic development envisions the rest of the worlds population moving progressively up the ladder of mass consumption. Clearly, the environmental implications of the global spread of mass consumption for resource use and environmental was te is staggering. In present times design culture also has greatly been influenced consumerism. Cities such as Las Vegas have dedicated there entire landscape to advertising to feed the need of consumerism. For the Utopian design at hand I have targeted the hospitality sector of the economy which attracts consumers owed to the hectic and fast-paced life we live today. I have chosen the Singapore Cricket Club for my bar and restaurant. The design is held together by the concept of network. Taking into consideration that the bar is the main attraction of a bar and highest revenue earning point in an FB. Using the concept of network my design directs all consumers towards the bar. The bar acts as the main attraction of my design which can be viewed from all levels and spaces. The unconventional feature of the bar is that it suspends 3000mm from the ground. As people walk through narrow corridors directing them towards the bar they are suddenly engulfed by the large open suspending bar and LED lighting panels from the ceiling going past 3 floors lighting up the entire design and focusing mainly onto the bar. The cuckoo club in London is a great example of how the bar acts as a key attraction in the premises. The entire space communicates glamour, drama and luxury. It represents a grand, dramatic film set with huge doors sweeping stairs, silk and voile drapes. The bar acts as a key feature covered entirely in gold sequins, set beneath a ceiling of diamond pattern panels of LED lighting (acrylic domes set into panels and then colour-washed across the whole ceiling), fringed with diamante beading. The lighting is flexible, varying from simulated daylight to pinks and purple in the night. The second case study chosen is Wine tower bar in UK. A 13 meter high wine tower forms the alluring centre point of the Radisson SAS Hotel lounge and bar at Stansted airport. The temperature controlled structure, constructed out of 6.5 tons of laminated glass, a steel core and a pyramid shaped roof, is fitted with an acrylic rack filled with 4,000 bottles of red and white wine. The enchantingly lit column not only serves as a large open wine rack but also functions as a theatre in which 4 graceful wine angels suspended on cables collect the bottles ordered by the guests. With the help of remote control and computer controlled winches, these women glide effortlessly up and down, whilst also slipping in a few acrobatics in the between. In conclusion Consumer culture has been incredibly successful. Not only has it been successful in satisfying our needs and desires, but it also has been successful in redefining what are needs are and expanding our desires. If we accept these desires as natural or inevitable, then consumer society seems natural and inevitable as well. Consumerism on the other hand does not only feed our desires but has left this earth with beyond reconcilable damages. Today are demand for goods is increasing beyond the capability of what our earth can come up with it. If our greed for consumption keeps increasing we will have to very soon give up our basic needs because our demands cannot be kept up with.

salinger Essay -- essays research papers

LIFE AND PHILOSOPHY OF J.D. SALINGER J.D. Salinger is one of the most renowned writers of his time. J. D. Salinger is most known for his controversial in the Catcher in the Rye. Salinger is also known for many of his writings such as Franney and Zooey, Nine Stories, and Raise High the Roof Beam, Carpenters. The summer of 1930 he was voted â€Å"The Most Popular Writer†. â€Å"Salinger is a beautifully deft, professional who gives us a chance to catch quick, half-amused, half-frightened glimpses of ourselves and our contemporaries, as he confronts us with his brilliant mirror images† (Lomazoff 1). In the novel, Catcher in the Rye, there is a relationship between the main character, Holden Caulfield, and Salinger. J.D. Salinger’s Catcher in the Rye explicitly demonstrates his life and philosophy in relation to his work.   Ã‚  Ã‚  Ã‚  Ã‚  Salinger was born January 1, 1919 in New York City. He was the second of two children. He had an older sister named Doris. His parents were Sol and Marie Salinger. His father was Jewish, and his mother was Scotch-Irish. He was raised up in Manhattan during 1920’s and early 1930’s. His parents enrolled him in McBurney Prep School in 1932. He flunked and his parents sent him to Valley Forge Military Academy, Pennsylvania. Later, after graduating he was drafted into the military and was known for carrying a typewriter around so he could write and publish stories. His perspective on life was molded by his experience in World War II. The ...

Land Law Essay

Proprietary estoppel protects a person who has a non contractual agreement over land but they have suffered a detriment due to them acting upon a reliance based on an assurance made by the claimant. There has been much discussion in recent case law and academic commentaries as to the elements which make up the nature of proprietary estoppel. Unconscionaibility is a major point for discussion in deciding whether it should be treated as a separate element or if it is linked into the three main elements. This essay will consider and discuss the nature of proprietary estoppel and the two views on unconscionaibility; whether there will always be unconscionaibility if there has been a non-performance of an assurance causing the claimant to suffer a detriment based on the assurance which they relied on or if unconscionaibility should be proven as a separate element in each case. The starting point of proprietary estoppel was in the case of Willmott v Barber (1880) where five criteria were laid down, which had to be satisfied by a person claiming proprietary estoppel and the courts applied these criteria to a wide range of proprietary estoppel claims. However these criteria were criticised for being too strict leading to the broader approach established in Taylor Fashions Ltd v Liverpool Trustees Co Ltd (1982) where Oliver J stated: ‘whether, in particular individual circumstances, it would be unconscionable for a party to be permitted to deny that which, knowingly or unknowingly, he has allowed or encouraged another to assume to his detriment’. Although the approach became broader there still remained essential elements which must be satisfied for a successful claim. The more modern approach towards proprietary estoppel is based on three main elements, firstly an assurance of land or property being made to the claimant, the claimant relying on the assurance which has been made and finally the claimant suffering a detriment as a consequence of relying on the assurance made. The main point for discussion and questioning in proprietary estoppel is the role of unconscionaibility and whether it should be treated as a fourth element which too must be satisfied in order for a claim to be successful or if unconscionaibility is interlinked with the other elements of proprietary estoppel. Proprietary estoppel acts as ‘a sword and a shield’ and can be used in one of two ways. ‘Put positively, the reason why it is possible to use proprietary estoppel to generate a property interest in a favour of a claimant despite the absence of the normal formality rules is because of the need to prevent unconscionable conduct. This is why unconscionaibility is the foundation of estoppel. It is the antidote to the otherwise fatal absence of formality. ’ This is one of the views on unconscionaibility which suggest that unconscionaibility is at the heart of proprietary estoppel rather than a separate element of it. The first element of proprietary estoppel is encouragement where the claimant’s belief that they would have some rights over land or property has been encouraged by the promisor and this could have been done actively or passively. Active encouragement is seen in common expectation cases where the claimant has been actively persuaded through an express representation as in Inwards v Baker (1965) where a son was actively encouraged to build on his fathers land in the expectation that it would be his in the future. Common expectation cases are dealt with more generously by judges, compared to passive cases, as the promisor has lead the claimant to have a reasonable belief that they would acquire the land therefore leading them to rely upon that assurance causing them to suffer a detriment. It would be seen as unconscionable in a common expectation case for the claimant to have been encouraged to suffer a detriment for the promisor to then go back on their assurance, meaning that unconscionaibility is instantly a running theme in the elements as it can be seen at the first instance and should therefore not be treated as a separate element. The encouragement could also be passive, for example a land owner standing by watching someone build on their land knowing that somebody is acting under a mistaken belief. The nature of a passive expectation made to the claimant can be distinguished in commercial and domestic cases as was seen in Cobbe v Yeoman’s Row Management Ltd (2008) where the House of Lords established that the expectation of an interest in land should not be vague in a commercial situation. The expectation should be for ‘a certain interest in land’ for proprietary estoppel purposes which was not the expectation held by Cobbe therefore the expectation was held to be too vague. Lord Scott stated ‘Unconscionaibility in my opinion plays a very important part in the doctrine of equitable estoppel, in unifying and confirming, as it were, the other elements. If the other elements appear to be present but the result does not shock the conscience of the court, the analysis needs to be looked at again. This statement shows how case law endorses the unconscionaibility approach as being interlinked with the other elements of proprietary estoppel however if all of the elements are not satisfied there can not be a claim for proprietary estoppel as is the case here. In domestic (family) cases, the nature of the expectation doesn’t have to be so specific as long as there is an interest or right in land that would amount to a significant expectation. The assura nce made must be clear enough so that claimant is found to have relied upon. Lord Walker stated in the case of Thorner v Major (2009) â€Å"There is no definition of proprietary estoppel that is both comprehensive and uncontroversial†¦the doctrine is based on three main elements, although they express them in slightly different terms: a representation or assurance made to the claimant; reliance on it by the claimant; reliance on it by the claimant; and detriment to the claimant in consequence of his (reasonable) reliance† One view on unconscionaibility stated that ‘Once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it’ therefore if it cannot be proven that an assurance existed then it wont be unconscionable for it to be withdrawn showing that unconscionaibility is a running theme within proprietary estoppel rather than a separate element. One difficulty in deciding these kinds of cases is that although an assurance has been made to the claimant in the way of a will, the claimant is also aware th at the will could be revoked at any time therefore the question to be asked is whether their reliance based on the assurance was adequate. The second element of proprietary estoppel is reliance where the claimant must have been encouraged to rely on the promisor’s assurance which has caused them to suffer a detrimental loss by changing their position and there must be a sufficient causal link between this in that the encouragement must have caused the detriment suffered. Reliance can not be treated as an element alone it has to have caused a change in the position of the claimant, if no detriment has been suffered then there can be no claim for proprietary estoppel. There are several ways in which the courts can show how the claimant was influenced to rely on the encouragement; firstly is by clearly showing that there has been a change in position by the claimants positive act, for example the claimant spending money on the land or making property improvements based on the assurance that it will become theirs, causing them to suffer a detriment. Where the claimant has acted in a way different to what he would had the assurance not been made nd relied on this can also show how the encouragement has influenced the reliance causing a detriment as in Jones (AE) v Jones (FW) (1977) where a son acted on the assurance of property becoming his left his job and house to live with his father, however had the assurance not had been made he would not have done this leading to the detriment that he suffered. There can be a presumption made that the claimant relied on the assurances given to them based on there conduct and in these cases the burden is put onto the other party to prove that the claimant did not rely on the promises made and this is hard to prove as it is a subjective matter based on the claimants state of mind. This was the case in Greasley v Cooke (1980) where the defendant did not have to prove that she relied on assurances as it was presumed from her conduct. The final element of proprietary estoppel is that the person must have suffered a detriment due to the reliance on the assurance which has caused a change in their position. The detriment suffered can be in many forms not just that of financial detriment although it must be substantial in making it unconscionable for the land owner to withdraw their promise of land to the claimant. Walton v Walton (1994) shows where financial detriment wasn’t the main detriment suffered, the claimant had suffered a personal detriment as he had spent years of his life relying on the assurance made to him that the farm would one day be his, and he couldn’t get those years of his life back. Public policy in formalities of contracts plays a major part in the deciding claims for proprietary estoppel. Section 2 Law of Property (Miscellaneous Previsions) Act 1989 states that (1) A contract for the sale or other disposition of an interest in land can only be made in writing and only by incorporating all the terms which the parties have expressly agreed in one document, or where contracts are exchanged, in each. This act stops informalities in land transfers where a claimant would be expected to sign up a contract but hasn’t done so, as in Cobbe, and this is where they would turn to proprietary estoppel to try and show that the detriment which they have suffered is due to the unconsionability of the removal of the assurance which they had originally relied on. Proprietary estoppel acts as a way around formalities and a form of protection for those who have not followed contractual formalities in the transfer of land. Why should people be able to use proprietary estoppel to make a claim for land where they have followed formalities and drawn up a contract as in Cobbe, it can be seen that it is not unconscionable for the promisor to withdraw as there is no contractual agreement. However in domestic cases where there wouldn’t always be an expectation of a legal contract to be drawn up proprietary estoppel can stop unfair decisions being made due to the lack of formalities where it would be unconscionable for the defendant to suffer a detriment due to an assurance on which they have relied. There are clearly two competing arguments against proprietary estoppel, the first being that ‘once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it. Indicating that unconscionaibility is a function of the three elements. If unconscionaibility was seen as a separate element then it would be pointless in having formalities as it wouldn’t matter whether it was unconscionable or not as long as the other elements had been satisfied. The second view on unconscionaibility is that of it being a separate fourth element and in some circumstance this can be seen as being successful for example in commercial cases where the first three elements of proprietary estoppel have been established but it would be unconscionable for the claimant to benefit due to the lack of formalities and contractual agreement.