Sunday, December 29, 2019

Changes in Fashion During the 1980s - 521 Words

The 1980 brought the art of being serious grown-up and working, careful makeup and colorful clothes the good the bad and the ugly. Some fashion abandoned history while others bloomed from it; the outlook was original and easygoing with velvet knickers and short cheerleader skirts. Bright colors and huge earrings were an obligation, teased hair, loud makeup were significant parts of the styles. His and her Rolex watches were the defining symbol of the yuppie couple. Short skirts, wide shoulders, and assertive lines linked all of these classic eighties designs for day and night. On the ski slopes the styles and colors of ski pants changed each season and ski boots themselves became more intricate every year. Leotards became high fashion sports had become more about style then game, Sneakers moved from fields to the place of working women. So did power dressing which main basics are various sized shoulder pads, Velcro, glitzy jewelry, silk, wool and cotton and bright colored spiked heel s. Women adapted to men’s clothing for their needs, with various styles of skirt and jacket becoming standard, shoulder pads added the width to the female form and lent an air of authority. Men were concerned about their appearance and looking good. Even underwear became controversial, with debates over boxer shorts, bikini briefs, and jockey shorts. More aftershave, hair products and even makeup were sold. For men, the power suit became common, narrow pinstripes, button down collars and fourShow MoreRelatedEssay on The Evolution of the 1960s and 1980s: Jimi Hendrix1091 Words   |  5 Pagesinfluenced this decade. In the 1980’s, there were also many influential musicians, singers, and songwriters that captivated the thoughts and movements of many people. Music influenced fashion and behavior in the 1960’s and 1980’s and these properties have been recognized throughout the years. Music went through an immense evolution in both of these decades. The fashi on and behavior that derived from music inspirations defined these two decades as individuals. The 1960’s and 1980’s have differences thatRead MoreHollywood Movies And Fashion Essay1405 Words   |  6 Pagesthe capacity to make not just a star of its leading women, but a fashion icon too. From Audrey Hepburn and Grace Kelly to Julia Roberts and Keira Knightley, via Mia Farrow and Catherine Deneuve, some of Hollywood s most successful stars owe a lot to their on-screen style. Moreover, during the 21st century, movies have been a powerful media in which to influence people’s style.   Movies gave society a great way to see vintage fashion, including how to wear period accessories that accompany the clothingRead MoreHow The Silver Screen Affects Women s Fashion Trends?1495 Words   |  6 PagesHow the Silver Screen Affects Women’s Fashion Trends? Today/Throughout History? Silver screen has the capacity to make not just a star of its leading women, but a fashion icon too. From Audrey Hepburn and Grace Kelly to Julia Roberts and Keira Knightley, via Mia Farrow and Catherine Deneuve, some of Hollywood s most successful stars owe a lot to their on-screen style. Moreover, during the 21st century, movies have been a powerful media in which to influence people’s style.   MoviesRead MoreMusic Has Impacted Our World1585 Words   |  7 Pagescultural revolution. During these times, we could see how many artists aimed at these concerns through their lyrics, but the eighties had a big impact in our society. During this decade, The United States felt more liberalistic, and New ideologies were presented to our society, also Sex and drugs became the focus of many of the lyrics expressed by the artists. The eighties were a different decade. People in The United States felt free to achieve anything that they would wanted to. The 1980s reflected theRead MoreMtv : The Decade Of Fashion1513 Words   |  7 Pages The Decade of Fashion Through TV influences people’s fashion, style, and makeup has slowly transformed from bright and bold to neutral tones over the years. Cable television became more accessible in the 1980s and by the middle of the decade 70 percent of the American population has a Cable Television that inspired people to follow popular TV shows’ fashion (Alexander). Dynasty came out as one of the most watched soap operas at the time and people began stealing fashion and makeup ideas from theRead More1950s Fashion Essay1059 Words   |  5 PagesFashion for women has become a major part of all decades and has changed constantly from day one. From one decade to another the trends and styles of clothes alternated drastically. The 1950’s started with long, flowy dresses. 1960’s moved to more playful, knee-length dresses. 1970’s was tight fitting clothes and platform shoes. 1980’s was all about bright colors. 1990’s included thrift shop clothes and more of a hip-hop style. Lastly, the 2000’s is all about short skirts and movie orientated clothesRead MorePolitics And Popular Culture During T he 1960s1279 Words   |  6 Pagesdiscovery and learning, the 1980s fought conformity and became a force to be reckoned with. It was now acceptable to express one’s individuality and the time to experiment until a person found out exactly who they were. America in the 1980s was inclined to challenge authority and tradition, as the people were vibing with attitude and vivid thoughts. This newly found confidence was introduce with the electron of Ronald Reagan, generating both social and economic change. Reagan’s restoration of theRead MoreThe Many Changes of Fashion Essay1557 Words   |  7 PagesWhat is Fashion? Fashion is a general term used to describe a style of clothing or practice used by people around the world. Fashion refers to anything that is a trend. Self-presentation is the most direct noticeable marker of fashion. Throughout history we have seen many changes in clothing, from the color, to the material used to make it. We have also seen the style in whic h clothing is made change drastically. Fashion communicates meanings that have individual and social significance. SocietyRead MoreThe Origination Of Hip Hop1237 Words   |  5 Pagescarrying the gospel of hip hop. He came of age in the South Bronx during the 1970s and used his charisma to rise to the rank of warlord in a local gang called Black Spades. After traveling to Africa, he decided to borrow a motto from an earlier decade: wage love, not war. He decided to use his influence to turn the Black Spades into a peaceful organization called the Zulu Nation. â€Å"Bambaataa had this vision of hip-hop as a force for social change,† says Chang. â€Å"He had the history and street credibility toRead MoreSocial Factors That Changed The World1366 Words   |  6 Pagesmore people are seen being involved in popular fashion trends and expressing themselves in ways they please because of the affordability. The sharply angled Vidal Sassoon hair style where women cut their hair sho rter and styled it in an angular way. This decade also started the trend of people wanting to look skinnier. Designers preferred models looked younger, thinner, and had longer legs. Social factors occurring at the time also effected fashion and helped represent people’s beliefs. Andrà © Courrà ¨ge

Saturday, December 21, 2019

What You Eat Is Your Business Essay - 1140 Words

In Radley Balko’s essay â€Å"What You Eat Is Your Business,† Balko argues that what we put into our bodies is our business, not the government’s, and that personal responsibility should be primary in our nutrition choices. I agree wholeheartedly. However, while I do agree that personal responsibility is paramount, in the new age of the Affordable Care Act (which had not been implemented prior to Balko’s writing), it is becoming hard to say that the government should stay out of my business, when healthcare is now, by law, the government’s business. Critics of personal choice argue, like David Zinczenko does in his essay â€Å"Don’t Blame the Eater,†. These two authors both help me understand each other that the government must regulate the fast food industry similar to how they regulate the tobacco companies. How absurd it is that the government needs to regulate my waistline? Balko declares that government policies are â€Å"bringing government between you and your waistline† (396). While there is no doubt that there is a problem with obesity, Balko hypothesizes correctly that government programs, which are meant to halt obesity, are instead incentivizing it. In the words of Balko â€Å"If the government is paying for my anti-cholesterol medication, what incentive is there for me to put down the cheeseburger?† (397). Further, with new legislation that requires insurers to give healthcare to people regardless of pre-existing, or even self-imposed medical conditions, we have completelyShow MoreRelatedWhat You Eat Is Your Business868 Words   |  4 Pagesâ€Å"What You Eat Is Your Business,† by Radley Balko In the article of Radley Balko, he considers obesity a problem in the nation. Balko believes that it is unhealthy for children to be eating bad food but it’s their choices to eat that food. Balko is saying that if people are eating unhealthy and are having health problems everyone shouldnt have to pay for their health problems. Balko says, â€Å"In other words, bringing the government between you and your waistline.† Basically he is saying that theRead MoreWhat You Eat Is Your Business894 Words   |  4 Pagesfavorable to society as a whole. But on closer investigation, it is easily seen that the governments influence on such a personal matter produces the antithesis of beneficial and ultimately aids in nurturing obesity. In Radley Balko’s essay â€Å"What You Eat Is Your Business†, he is rightfully insists that the anti-obesity regulations and restrictions set by the government wrongfully alleviates American consumers of their individual responsibility f or their own well-being by transforming health care from aRead MoreWhat You Eat Is Your Business1315 Words   |  6 Pageseven the family of 4, finding time to eat a healthy meal fells like it can be impossible. Some might argue everyone can find time to eat a healthy meal, but as a full time college student with a family of 4 with another kid on the way. Even the little time I do have at home doesn’t change that I have not had a chance to get to the store for two weeks to buy food. Given the little time and lack of food, the options can be slim, but fast food addictions can cause you to make bad choices too. So when doesRead Moreâ€Å"What You Eat Is Your Business† reflection1000 Words   |  4 Pagesâ€Å"What You Eat Is Your Business† reflection The common thought of most Americans living in the United States that it is the greatest country on planet earth, and second is not even close. They believe this notion because of the freedoms this great nation was founded on: The freedom of religion, the freedom of speech, the freedom of assembly. These freedoms turn into more simplistic generalities that are assumed and exercised by Americans daily, such as the freedom of choice. Although the freedom ofRead MoreWhat You Eat Is Your Business By Radley Balko863 Words   |  4 Pagesor that Americans have many diseases that contribute to being obese. â€Å"What You Eat is Your Business† by Radley Balko expresses that people are at fault for making such unhealthy food choices. Others argue that the food industry is to blame for being so unhealthy. According to David Zinczenko in â€Å"Don’t Blame the Eater† he blames the fast food industry as well as the consumer. Zinczenko asks â€Å"shouldn’t we know bet ter than to eat two meals a day in fast food restaurant’s?† (392). So, who is to blameRead MoreAnalysis Of What You Eat Is Your Business By Radley Balko833 Words   |  4 Pagesâ€Å"What You Eat Is Your Business† by Radley Balko Your Are In Control It has become common today to dismiss the idea of personal responsibility, however, Radley Balko,   author of â€Å"What You Eat Is Your Business,† has not. The article, published on Monday 23, 2004,on the website Cato Institute, reminds us of the importance and significance of personal responsibility in dealing with obesity.   Additionally, he argues that   government’s   attempt to   restrict American diets and without consumers being   heldRead MoreWhat You Eat Is Your Business By Radley Balko And Junking Junk Food By Judith Warner1223 Words   |  5 PagesWhether or not a person wants a burger and french-fries’ or a salad from the salad bar, the decision should be up to him/her. Two articles share views on food, â€Å"What You Eat Is Your Business† by Radley Balko and â€Å"Junking Junk Food† by Judith Warner. These two authors wrote articles about how they felt about food and how it’s related to obesity. However, Radley Balk o would not approve of Judith Warner’s views on food for the reason that the two authors have different viewpoints on the aspect of theRead MoreWhat You Eat Is Your Business By Radley Balko And Don t Blame The Eater By David Zinczenko Essay775 Words   |  4 PagesWhen it comes to the topic of obesity, most will readily agree that it is a growing dilemma. This argument has many writers bringing different responses. Two explanations are debated in What You Eat is Your Business by Radley Balko and Don’t Blame the Eater by David Zinczenko. Both pieces create a good stance on the topic of obesity. Balko’s piece, however, has a better all around flow, organization and consistency. In Don’t Blame the Eater, David Zinczenko composes his opinion on the fast foodRead MoreNever Eat Alone1360 Words   |  6 PagesNeCaroline Madden Prep for Profession Jonathan Flom 18 March 2013 Never Eat Alone Never Eat Alone by Keith Ferrazzi is extremely applicable to the performing arts business. The book emphasizes on the importance of knowing your own brand, connecting with others, and relating to others on a human level. To be in the acting business, you need to know the package you are going to present yourself with, you need to be able to work well with others, and in the audition room make a human connectionRead MoreThe Problem With Obesity And Obesity995 Words   |  4 PagesHave you ever drank a pop or soda? I’m sure most people would answer yes to that question. But a better question is do you really know what is inside the can? Everything we put in our body effects us. From vegetables to doughnuts, everything carries nutritional facts with it. Some are better than others. But one thing is for sure; the nation is in a crisis with obesity. Weight gain is on a rise and more and more of the population is getting bigger and bigger. This can be credited to the nutritional

Thursday, December 12, 2019

Human Factors in Organizational Design - MyAssignmenthelp.com

Question: Discuss about the Human Factors in Organizational Design. Answer: Introduction Health and safety regulations are necessary to make sure that every worker works in hazard-free environment. Workplace Health and Safety (WHS), which is often referred to as Occupational Health and Safety (OHS), is the set of regulations and assessment of the risks that may have impact on the health, safety and welfare of the people who work at different workplaces, effectively meaning every employee of the country (Australia, 2014). However, this act encompasses every stakeholder of any organisation and seeks to protect everyones health safety. Business owners and even government organisations are obligated to comply to some legal rules and regulations that are designed towards protecting the health and safety of the people who are involved with the organisation in any way. The following report would be looking into the current WHS conditions of BizOps and give comprehensive and realistic ideas relating to how can the current conditions be made to be better and the policies more integrated into the operations of the company. BizOps Enterprises is dedicated to ensure all of its employees with a safe and secured working environment. Every employee has to feel secured while working here and it is the duty of the organisation to do that. These policies are formed in accordance to the legislative obligations that the company has to the laws and WHS regulations of the state. As a demonstration to this commitment of the organisation, BizOps take prompt action against any and every unhealthy and unsafe working situations. All workers are trained about and communicated to regarding the health and safety practices and procedures of the company. The health and safety representatives of the organisation are selected and appointed according to the state and territorial legislations. These representatives have the authority that are vested by the state legislations. To ensure the workplace health and safety are of the highest standards, BizOps regularly consults on WHS with its staff and employee representatives and a lso, if deemed necessary, with the contractors and suppliers of the company as well. First aid attendant: The company has an attendant who is always on alert and any issue regarding any sort of injury or safety is immediately given attention by the attendant. The attendant is trained by the organisation themselves to equip the personnel with the knowledge and skills to tackle any unpredicted situation that may arise. Emergency evacuation procedure: The company has clear escape plans and routes all over the building and clear directions about the escape routes are put up on the walls of BizOps. This make it easier for the staff to evacuate quicker and calm manner without causing panic. WHS audit: BizOps conducts regular internal audits of its WHS policies to ensure that the procedure and policies are up to the mark and can face adversities in any case. The audits help the organisation to understand if any upgradations are needed or any modifications are required to the existing policies. The organisation also has strict policies regarding reporting of any hazards or incidents that pose to be a threat to or compromise the WHS of BizOps. The entire building is smoke free and fire and smoke detectors are installed everywhere that ensure no fire related hazards happen. BizOps has a WHS policy that adheres to the state legislations and conforms with the laws of the country. However, the existing policies can still be enhanced and a better policy can be adopted. To achieve this, the company has to analyse all aspects and have proper ideas relating to the scope and framework of the issues that may arise. It should be clearly defined what are the responsibilities of the company and how can those be achieved and which strategies may facilitate in this process. The organisation also has tables and charts that segregate and classify every possible type of hazard that may happen in the workplace and also how can they be prevented or tackled. While investigating the past WHS incidents of BizOps, it has been noticed that the staff and employees are almost never consulted about hazard identification or assessment. Their suggestions about forming and developing risk controls are also not taken into account. Moreover, some information is given only to the employees, making it difficult for the work students and interns to know about them and take precautions. BizOps has to come up with a system that would be helpful in making more decisions, where the staff and every employee would be consulted to form the risk assessment and risk control structures. The staff should be consulted and their suggestions and inputs have to considered while forming the new policies of the company. In recent times, BizOps had to grant two employees work offs because they had sustained injuries at the wotrkplace. One was due to prolonged sitting at the computer because the employee was tasked with data entry into the computer, and the other was suffered by a work experience student who had injured her lower back while lifting goods in the warehouse. The two incidents that were recorded in the last months are the two key points that would serve as the basis of the formation of the new policies. These employees are going to be consulted as they would be the best to depict the scenario that happened and can also help to understand what could have been done to prevent them. The suggestions that would be given by these employees would serve as the key components for the new policy outlines. Summary of the key points The specific conditions and situations of the incidents have been recorded and the suggestions and perspectives of these staff have also have been noted down. The WHS policy of BizOps are being overviewed and the occurred instances and the prevailing policies are being compared to understand the discrepancies and gaps that led these to happen in the first place. The new policies should be made and formed after the staff of the organisation are consulted, because they are the persons who face the situations that have potentials for safety hazards. Hence, they would be the most knowledgeable about what are the causes or which things lead to the safety issues. Involving them and consulting the employees would be the best way to create the new WHS policy for BizOps. Hazard report number 1 Area of work Data Entry Date Specific hazard location Data entry desk Reported by Contact phone number Contact email Hazard description: Risk likelihood legend Grade Level of likelihood A Expected (will occur regularly) B Probable (will occur at some stage) C Possible (could occur) D Improbable (could occur but unlikely) E Rare (may occur but in limited situations) Risk impact/ consequence legend Grade Level of impact 1 Insignificant 2 Minor 3 Moderate 4 Major 5 Catastrophic Risk categorisation matrix Level of likelihood Level of impact 1 (Insignificant) 2 (Minor) 3 (Moderate) 4 (Major) 5 (Catastrophic) A (Expected) Medium Medium High Extreme Extreme B (Probable) Medium Medium Medium High Extreme C (Possible) Low Medium Medium High High D (Improbable) Low Low Medium Medium High E (Rare) Low Low Low High Medium Suggested controls: The employee was immediately taken to a doctor, for which the organisation paid. The company also sanctioned for a long leave for the employee to help him recover from the injury sustained Recommended control(s): The employee must first be allowed to treat himself to recover from the injury. That is the foremost priority. The employee should be given the time to regain his strength. The employee should be consulted about what he thinks happened and why did he injure himself The employee must be asked about his ideas and suggestions regarding what could have been done to prevent this situation The new policies can use his suggestions and inputs to form the strategies that can aid in situations like this in the future as well as plans to reduce the possibilities for the occurrence of these situations Person responsible Controls to be completed by: Approved by organisational unit head/officer Completion verified by health and safety representative (HSR) Appropriate training program Based on the risks that relate to computer data operators, BizOps has decided to train all the other operators regarding how to work in a manner that would not cause any such incidents in the future. The operators would be given proper ideas regarding how should they sit and even operate in the office. What should be the right thing to do when an employee feels uncomfortable after working for a long period of time. The computer data entry operators would be given ideas about how can they reduce their own physical pain by using certain techniques. Despite a lot attention being given to the employee safety in BizOps, the focus on the safety of the work experience students is still very low. This needs to be given attention and policies need to be made that would also make the organisation a safe place for the students who come here to gain knowledge. A work experience student injured her lower back from having to shift goods in the warehouse. This cannot be tolerated if the company looks to make it a good and safe working place. The company wishes to change its current condition and make it a point to ensure safety and health security to all of the people involved, including the students who work here for experience. In order to achieve this, BizOps has to train the work experience students and let them know how to use the handbook and the guidelines, so that they can better avoid the situations that can lead to hazardous situations. They also have to trained regarding equipment handling and other potentially hazardous work they execute. Accident at the warehouse Details of incident (e.g. to a worker or visitor) and treatment Date of incident Time of incident Nature of incident Near miss First aid Medical treatment/doctor Name of injured person Mary Smith Activity in which person was engaged at the time of the incident/injury Mary was checking her phone and tripped over a box of documents Exact site location where incident/injury occurred Warehouse Nature of injury, e.g. burn, fracture, sprain Ankle sprain, bumped her head Specific location of injury on body, e.g. upper left arm Ankle, head Treatment given on site First aid, bandage Name of treating person Witnesses to incident Name Phone contact Name Phone contact Description of incident Mary Smith was walking while checking her phone and did not notice the box of documents next to the filling cabinet. She tripped over and sprained her ankle and bumped her head. Immediate response actions (e.g. barricades, isolation of power) to stabilise the situation She was given first aid in the warehouse itself by the first aid attendant. Then she was taken to a local hospital and was given two days off from work. Person reporting Signature Reported to Name Position Name Position Conclusion From the above recommendations and hazard analysis of BizOps, it is evident that the company is on the right way to resolve the issues it has been facing regarding the health and safety issue, in the recent times. BizOps will be changing a lot of its operational policies to make sure that the new WHS policy of the company is more inclusive and gives the employees even more health security, making the company a much safer and secure place to work at. References and bibliography Australia, S. W. (2014). Model Work Health and Safety Regulations 2011.Division 2High Risk Construction WorkSafe Work Method Statements. Australia, S. W. (2014). Work-related traumatic injury fatalities, Australia 2013.ACT: Canberra. Australia, S. W. (2015). Exposure to Multiple Hazards Among Australian Workers.Safe Work Australia, Canberra. Baicker, K., Cutler, D., Song, Z. (2017). Workplace wellness programs can generate savings.Health affairs. Blewett, V., Rainbird, S., Clarkson, L., Etherton, H., Paterson, J. (2014). Strategic engagement: including youth in the development of the Youth Work Health and Safety Strategy for South Australia. InHuman Factors in Organizational Design and Management XI: Nordic Ergonomics Society Annual Conference Proceedings(pp. 711-716). Chan-Mok, J. O., Caponecchia, C., Winder, C. (2014). The concept of workplace bullying: Implications from Australian workplace health and safety law.Psychiatry, Psychology and Law,21(3), 442-456. Chmiel, N., Fraccaroli, F., Sverke, M. (Eds.). (2017).An Introduction to Work and Organizational Psychology: An International Perspective. John Wiley Sons. Dawkins, S., Sanderson, K. (2017). Workplace mental health: An international review of guidelines. Dollard, M. F., Bailey, T. S. (Eds.). (2014).The Australian Workplace Barometer: Psychosocial safety climate and working conditions in Australia. Australian Academic Press. Lay, A. M., Saunders, R., Lifshen, M., Breslin, F. C., LaMontagne, A. D., Tompa, E., Smith, P. M. (2017). The relationship between occupational health and safety vulnerability and workplace injury.Safety science,94, 85-93.

Thursday, December 5, 2019

Express Trusts free essay sample

Declaration – where a title holder expresses his or hers intention to hold their property on trust for another. 2)Transfer where title is transferred to a person with instructions that it be held on trust for another. -inter vivos ? occurs during the life of the person (referred to as a ‘settlement’). It may be for consideration or a gift. (NB: Equitable Assignment check list). -post mortem ? occurs after the death of the person (in their will). 3)Direction – where a beneficiary instructs their trustee to hold an interest on trust for another person. Kinds of Trust Trusts are either: 1. Express Trusts (being examined in this lecture). 2. Charitable Trusts 3. Resulting Trusts (intention presumed) 4. Constructive Trusts (used as a remedy) Three Certainties The law of equity states that a trust must satisfy the 3 certainties. If any of the 3 certainties do not eventuate, the trust will fail: ?Certainty of Intention – it must be clear that the settlor or testator/testatrix (person creating a trust) wanted the trust to exist. We will write a custom essay sample on Express Trusts or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page ?Resulting (intention presumed) and Constructive (used as a remedy) trusts are immune from this certainty. Intention does NOT need to be expressed through the word ‘trust’. Only the elements of a trust need to be present. Commissioner of Stamp Duties v Joliffe (1920) 28 CLR 178 -At this stage Qld law stated that a person could only have 1 bank account. -Joliffe set up a 2nd bank account, as a ‘trust account’ for his wife. -When Joliffe’s wife died, death taxes/duties were owed on the account. -Joliffe went to court and argued that he lied and wasn’t actually holding the account on trust for his wife – it was for him. HC agreed with Joliffe. -Rule: If it is possible for the creator of the trust to display to the court that he never/did intend for a trust to exist, the presence or absence of the words ‘trust’ or ‘trustee’ is irrelevant. -Clean Hands: There appears to be an issue here of equity’s requirement that all parties relying on equity have ‘clean’ hands (issue seemed to have been ignored here). -Evidence: Burden of proof will fall on whoever wants to prove a trust is in existence. ~Inter vivos trust? ritten evidence or oral evidence will be accepted. Factors that will be important in determining whether or not a quistclose trust exists include: (a) the presence of a separate bank account and; (b) letters indicating intention. Barclays Bank Ltd v Quistclose Investments Ltd [1970] was incorporated into Australia law through Classifying the Quistclose Trust: ?QC paid the money to RR, who is the beneficiary? ? must be shareholders? Hence if RR liquidates, than money should go to shareholders, not QC. ?Ford Lee ? mutual intention in Quistclose was that if company was an ongoing concern, dividends should be paid. If you examine judgment in Quistclose there is no mention of such a condition. ?Camerson Stewart’s argument in RSL ? the creditors in Quistclose don’t receive any beneficial interest (based on Justice Brighton’s argument in Mercantile Mutual v Farrington 1996). ?Twinsectra ? case in House of Lords, rejected the concept of a trust with two limbs. -It removed Quistclose Trust from the category of express tr usts all together. Travel agency was collecting airfare bookings and passing airfare funds onto airline. When travel agency went broke, the airlines argued that the funds held by the travel agency, were held on trust for the airline. -NSW Court of Appeal found there was a trust of the funds in question. -Problem: Customers of the airline had no intention of creating a trust. However this was deemed irrelevant as the contractual agreement between the airline and the travel agency had created an express trust for the funds. Issue in both Re Kayford Ltd (in liq) and Stephens ? The certainty of intention element was violated as these cases basically state that it’s not necessary for the settlor (testator/testatrix) to provide intention.