Three Main Stages in a Listening Lesson and Activities Suitable For Essay

Three Main Stages in a Listening Lesson and Activities Suitable For Each Stage - Essay Example It is evidently clear from the discussion that when the learners have been able to listen accurately, they are in a better position to refine their understanding of the grammatical structure of the content being taught and also apply it to develop their own vocabulary. The planning of a listening lesson should be systematic  so that the teacher can prepare the students for listening just before the actual listening lesson begins, and continue to prepare them during the actual listening lesson and even after the lesson. The systematic planning is necessary, owing to the fact that learners can experience problems in understanding and the subsequent interpretation of the content of the listening lesson. Thus, there are three main stages that a listening lesson should undergo in order to enhance the chances of the students’ understanding, comprehending and interpreting the content accurately. These stages are: Pre-listening is the first stage in a listening lesson, which occurs before the actual listening of the text by the learners begin. Pre-listening is a vital stage in the listening lesson, due to the fact that it acts as a preparation stage for the learners to get an idea of what they are going to listen. One of the major goals why the Pre-listening stage is important in a listening lesson is that it is the necessary stage for offering the necessary motivation to the learners. Motivation is important because it is the element that arouses the interest of the students in the text, making the students ready to listen keenly to the content. Therefore, the role of the teacher at the Pre-listening stage should be that of motivating the learners through creating interest and raising their curiosity regarding what the listening text contains.

MATLAB Dynamics & Control Assignment Example | Topics and Well Written Essays - 4500 words

MATLAB Dynamics & Control - Assignment Example Furthermore, both the time constant and dead time vary with the size of the step-change. The process gain is affected but it is affected only in half of the cases (see Concentration A, see below). †¢ Select a set of dynamic process constants resulting from one of the step-changes that you have tested, and use these to calculate initial values for the constants in each of the three different controller equations (P, PI & PID). Proportional control: It is simple, provides rapid adjustment of the manipulated variable (MV). Does not provide zero offset, although the error is reduced (E>0). It increase speeds in the dynamic response. It can cause instability if improperly tuned. Integral control: It is simple, achieves zero offset (E=0). It provides adjusts the manipulated variable (MV) in a slower manner than the proportional mode –this can lead to poor dynamic performance. It can cause instability if improperly tuned. Derivative control: It is simple. It does not influence the final steady-state value of the error (E). It provides rapid correction based on the rate of change of the controlled variable (CV). It can cause undesirable high-frequency variation in the manipulated variable (MV). †¢ Once you have chosen your optimal control scheme, justify why you have selected it. You can use various methods of assessing controller performance in order to reach your decision: rise time, peak overshoot ratio, decay ratio, settling time, IAE, ISE, ITAE. You are not expected to use all of these, but at least two should be used and compared with each other in relation to optimizing your controller constants. †¢ Test your control loop for its ability to cope with a disturbance (e.g. in the concentration of feed chemical, or the temperature of the cooling water), and also for its ability to move the process to a new operating region by making a step-change to the set-point (i.e.

Ethics in Psychology and Criminal Justice

Ethics in Psychology and Criminal Justice Ethical behavior is important within any discipline whether it be automobile mechanics or brain surgeons. Two disciplines in which ethical behavior is especially important are the disciplines of criminal justice and psychology due to the vulnerable state of the individuals which are encountered on a daily basis. Straying from compliance of ethical guidelines in either of these disciplines could result in mental damage in psychology, false arrests or acquittals in criminal justice, or termination and dishonor within either discipline. This manuscript discusses a couple ethical dilemmas within the disciplines of psychology and criminal justice as well as provides examples of each. The manuscript also briefly discusses the similar variables which make each discipline sensitive to ethical behavior. Ethical Dilemmas in Psychology and Criminal Justice Within any profession, whether it is a psychology, law enforcement, news casting, or even an automobile mechanic, an individuals integrity plays a pivotal role in how successful their endeavors turn out. Integrity, as defined by the Merriam-Webster Online Dictionary, is firm adherence to a code of especially moral or artistic values (Integrity, 2010). One whose integrity is compromised may be perceived as irresponsible, dishonest, and possibly even immoral. One thing that affects ones integrity is whether or not the individual conducts themselves in an ethical manner. Ethics within in a profession are a set of moral principals used to determine whether a certain behavior is right or wrong. Most disciplines have an ethical code whether it is implied or actually documented. For example, the American Psychological Association has a set of ethical principals published through which psychologists may judge whether a particular behavior or action is ethically sound (American Psychological Association, 1992). Alternatively, automobile mechanics have no generally accepted, published, ethics code. In a case such as this, establishments may be certified by different organizations which have developed an ethical code or they may develop one of their own (Mechanics R Us, 2010). This manuscript will discuss some ethical dilemmas which have been encountered and studied within the fields of psychology and criminal justice. Literature Review The American Psychological Association published a set of guidelines and codes which govern ethical behaviors within the psychological field (American Psychological Association, 1992). These codes cover most if not all aspects of psychology from therapy to research. It is upon this foundation that the choices of ethical dilemmas within the field of psychology are based. Also based upon these ethical guidelines Sherwin (1998) made a statement regarding the effects of unethical behavior upon the vulnerable individuals that psychological professionals encounter on a daily basis. Peternelj-Taylor (2002) and Lambie (2005) both provided examples of ethical dilemmas professionals within the psychological field may encounter. Peternelj-Taylor writes on the dilemma of over- and under-involvement with patients. Wartenburg (1990) discusses how the ideal amount of involvement for a professional within the psychological field to have with a client lies in an area called transformative power. Everett and Gallop (2001) went on to describe the ideal purpose of transformative power. Lambies (2005) composition involved the divulgence of suspected child abuse by school counselors. Crenshaw, Lichtenberg, and Bartell (1993) as well as Sechrist (2000) performed analyses that found problems in the amount of times that suspected child abuse is reported. Wilson, Ireton, Wood (1997) discussed how this dilemma ranks high among the concerns of helping professionals. The decision to report suspected child abuse is governed not only ethically but legally as well. In 1974, the National Child Abuse Prevention and Treatment Act (PL 93-247) provided a definition of child abuse (42 USCS 5101). Most states have also enacted statutes and laws which make divulgence of suspected child abuse required by law North Carolina General Statutes (2003). The differing professions within the field of criminal justice are also governed by sets of ethical guidelines. One ethical dilemma which is encountered within law enforcement is the use of excessive force. The case of Rodney King provides an excellent, high-profile example upon which to base the effects of this dilemma (Cannon, 1997). Schoch Lin (2007) found that, even several years after the event, a degree of civil unrest as well as a deep seated mistrust of the criminal justice community still exists. Vidmar (2002) discusses the ethical dilemma of introducing prejudice within the courtroom. He uses examples of cases in which he was called to analyze the amount of prejudice including Regents of the University of California vs. Genentech (1999) and R. v. Reynolds (1997). In these cases he found that it does not take much for prejudice to find its way into the courtroom setting and affect the opinions of those involved. Discussion Ethical Dilemmas in Psychology As one may easily ascertain, ethical behavior in any aspect of psychology is incredibly important. In many instances, those that participate in psychological research or receive a treatment of some sort from a psychologist are in a vulnerable state of mind. Sherwin (1998) said it best stating without a strong principle of respect for patient autonomy, patients are vulnerable to abuse or exploitation, when their weak and dependant position makes them easy targets to serve the interests (e. g. financial, academic, or social influence) of others (p. 20). In cases such as this, the psychologist must be incredibly cautious with the actions they take or risk causing damage that may take years to treat or may even be irreversible. Consequences against the psychologist may include having their qualifications questioned or possibly even legal actions. The ethical guidelines for the discipline of psychology are published in the Ethical Principals of Psychologists and Code of Conduct (American Psychological Association, 1992). In this section the manuscript will cover some ethical dilemmas which have been discussed within published literature. One ethical dilemma that psychologists may encounter involves relationships with patients outside of the patient-therapist or patient-researcher relationship. Peternelj-Taylor (2002), a nurse who worked as a team leader on a sexual offender unit of a maximum security forensic hospital, discussed this dilemma at length. Within the manuscript, the researcher discusses psychologists over-involvement and under-involvement with a patient. Over-involvement with a patient includes relationships past patient-therapist relations including friendships or sexual relations with patients. Under-involvement includes behavior which borderlines ignoring the patient which includes avoidance of patients or not exploring or addressing patient problems with sufficient detail. As one may imagine, either one of these instances may be harmful to not only the patient but also the therapeutic integrity of the psychologist. During patient-therapist interaction, it should be the goal of the psychologist to remain in an area between the two extremes of over-involved and under-involved power assertion. Wartenburg (1990) refers to this area as transformative power which focuses upon a sort of partnership with the patient. In patient-therapist relationships that maintain a transformative power relation, the focus is placed upon working with the patient in resolving their problems rather than overtop or in spite of. Everett and Gallop (2001) stated that the goal of transformative power is mutual liberation from dependency (for the client) and from being depended on (for the professional) (p. 124). In essence, this expresses what should be the ultimate goal of the patient-therapist relationship. Another ethical dilemma faced within the psychological profession is divulging information about suspected child abuse or neglect that was obtained during therapy. Lambie (2005) composed a manuscript discussing how this dilemma affects professional school counselors. One would assume that, with legal statutes requiring divulgence, the decision to report instances of suspected abuse would immediately be reported as soon as it is encountered though this is not always the case. In an analysis by Crenshaw, Lichtenberg, and Bartell (1993) the researchers found that, in many instances, helping professionals choose against reporting suspected abuse. Additionally, a study by the Federal National Child Abuse and Neglect Incidence Study found that school personnel only reports a small percentage of suspected abuse cases to Child Protective Services (Sechrist, 2000). Research has found that encountering a suspected case of child abuse is high among the fears of helping professionals (Wilson, Ir eton, Wood, 1997). It has been said that, while professionals are aware of their legal duty to report such cases, procedural uncertainty about how to go about reporting among other things are deterrents (Lambie, 2005). The decision of helping professionals to report suspected abuse is governed by both legal and ethical guidelines. Lambie (2005) discusses how professional ethics are in place to guide professionals throughout their ethical decision making. Within these ethical guidelines is a subgroup of ethics called mandatory ethics. Lambie goes on to discuss how the reporting of suspected child abuse falls under these mandatory ethics which crosses barriers into all disciplines. In 1974, the National Child Abuse Prevention and Treatment Act (PL 93-247) was enacted by Congress which defined child abuse as (42 USCS 5101): Physical or mental injury, sexual abuse or exploitation, negligent treatment, or maltreatment of a child under the age of eighteen or the age specified by the child protection law of the state in question, by a person who is responsible for the childs welfare under circumstances which indicate that the childs health or welfare is harmed or threatened thereby. In addition to this act passed by congress all of the states in the United States have passed statutes that make it illegal for an individual who is aware of an instance of child abuse not to report it (North Carolina General Statutes, 2003). Based upon these laws and statutes, it is not only ethically required that helping professionals report suspected child abuse but failure to do so may also result in legal ramifications as well. The field of psychology provides an important service for those that are having trouble coping with a mental disability or other psychological aspect of their life. As was mentioned earlier those that see a psychologist as a patient are, many times, in a psychologically vulnerable state. This is why it is especially important for those within the field of psychology to follow the ethical guidelines developed for their field as closely as possible. Those that are steadfast in their ethical behavior help to ensure that their patients receive the best treatment possible and reduce the possibility of inflicting any psychological damage upon the patient. Ethical Dilemmas in Criminal Justice Just like in the discipline of psychology, it is also exceptionally important to follow ethical guidelines within the discipline of criminal justice. Those whose profession falls within the discipline of criminal justice find themselves in an authoritative role amongst those around them. This fact puts the individual in a position of having power over others. If the individual is not cautious, this power may be easily exploited. Again, as with psychology, dire consequences may be suffered. In some cases, innocent individuals may be wrongfully accused and convicted while the true guilty party is freed in which case justice is not served. Police officers who stray from ethical behavior risk termination as well as having their reputation tarnished within their community. These facts make it necessary for those in criminal justice, just like those within the field of psychology, to follow strict ethical guidelines as well (See Appendix A). Within this section the manuscript will discuss some of the ethical dilemmas that are encountered within the field of criminal justice. One action that a police officer must inevitably take part in is the use of force. The action of applying force is not unethical in itself though ethics do come into question when the use of force gets to the point of becoming excessive. In any case, excessive force is any force used beyond what is necessary to subdue an assailant. One high profile case through which excessive force by law enforcement was brought to the forefront is the case of Rodney King (Cannon, 1997). During this incident, a video was taken of Los Angeles Police Department officers striking King repeatedly with batons after he was lying on the ground. Unethical behavior, such as was displayed in this case, is not only damaging to the individual performing the action, but it is also damaging to the law enforcement community as a whole. The use of excessive force by an officer of the law may lead to termination and, more than likely, legal repercussions such as restitution, prison time, or both. Actions such as this may also lead to an overall mistrust of the law enforcement community by individuals within the public which in turn may lead to civil unrest. Referring back to the Rodney King case, many years after the fact tensions are still high within the Los Angeles community as a result of the incident as well as the occurrences that followed (Schoch Lin, 2007). This should be a major concern due to the fact that law enforcement, as well as the other professionals within the criminal justice community, are in place to serve and protect the public and are required to be trusted when the time comes to perform their duty. Another ethical behavior that must be practiced within any criminal justice profession, as well as any other profession, is the elimination of prejudice. Prejudice may be presented in many different forms including prejudice by race, gender, social standing, or any other individual criteria. One area of criminal justice in which prejudice is particularly damaging is during jury selection. If a seated jury is introduced into the courtroom with a preconceived prejudice based upon some characteristic of the case, it may, in fact impede upon an individuals right to a fair trial. In most instances, prejudices may cause an individual to draw conclusions about a defendants guilt or innocence before the evidence against the defendant is even presented. There are many sources of prejudice, some of which include media publicity, community involvement, gossip, and rumors (Vidmar, 2002). It is for this reason that jury selection for any given case is, at times, a long a drawn out process. Jury selection is utilized to remove any individuals which may house some of these prejudices, such as family and friends of any individuals involved in the process, or any individuals that have been affected in any way by the type of crime in question. Vidmar (2002) performed several case studies upon court cases and their involvement of pre- and midtrial prejudices a few of which the following paragraphs will summarize. One case that Vidmar (2002) discusses is the case of Regents of the University of California vs. Genentech (1999). The case involved patent infringement on the human growth hormone Protropin. The jurors had been chosen and a date for the trial had been set. Before the trial, defense lawyers had discovered that Genentech had pled guilty in a federal case involving off label promotion of Protropin and had to pay $50 million. Obviously the defense lawyers were concerned that this information, if brought to light to the current jurors, could affect the outcome of the trial. The judge refused to delay the trial but did instruct the jurors to refrain from reading any news articles that involved the company Genentech. During the trial, the jurors were in a waiting room waiting to be called into the trial and one of the jurors brought with them a copy of the Oakland Tribune to read during the wait. When the juror turned to the business section of the paper one of the headlines stated what ha d happened in the previously mentioned case Genentech was involved in. According to reports, there is evidence suggesting that several jurors also observed the same headline. Obviously, in a case such as this, the jury pool had been tainted to a certain degree with prejudice. Another case study discussed by Vidmar (2002) involved the case of R. v. Reynolds (1998). The case dealt with a mother named Louise Reynolds that had been charged with stabbing her 7-year-old daughter 84 times. During this period, a great deal of community hostility had been directed towards her after a memorial poem of her composure had been published within the local newspaper. The defense had presented an alternative means through which Ms. Reynolds daughter could have been killed which involved a pit bull near the crime scene that was found covered in blood. The body of the child was then exhumed and examined by two forensic scientists whose findings strongly supported the alternative means presented by the defense. These results were not published within the local newspaper but were covered in nationally circulated newspapers. In preparation for a motion for a change of venue, Vidmar conducted a survey assessing the level of hostility that still existed towards Ms. Reynolds. Out of the respondents, 75% said that they were capable of giving an unbiased decision towards the case. Of the same group that was surveyed, only 45% stated that a non-guilty verdict would be a satisfactory verdict within this case. This gives the indication that even though evidence had been presented in support of Ms. Reynolds innocence, the hostility that was introduced as a result of the published poem still lingered to a degree within those surveyed prejudicing their decisions. As is evidenced above, ethical behavior is detrimental to the proper transaction of justice. Unethical behavior within the criminal justice community may result in civil unrest, false convictions, or worse. The daily interactions of those within one of the many criminal justice professions provide ample opportunities for abuse of power and dishonesty as well as many other unethical behaviors. Therefore it is vitally important for those within the criminal justice community to be vigilant in their endeavors as well as strive to complete their duties in an ethical manner. Conclusion As one can see both the disciplines of psychology and criminal justice require strict ethical guidelines if they are to be professionally and effectively implemented. Professionals within both disciplines interact on a daily basis with individuals that are within a vulnerable state. The effects of unethical behavior within the confines of these disciplines can be tremendously harmful to both the professional as well as the individual that the professional is interacting with. Professionals within the field of psychology risk losing their practice as well as legal repercussions while the patients that are victim to the unethical behavior risk further damage to their already vulnerable mental state. Professionals within the criminal justice community risk termination, a tarnished reputation, and possibly even legal repercussions as well. The effects of unethical behavior within criminal justice deprive the affected individuals of their right to justice while, in some of the more extrem e cases, may even lead to civil unrest and a deep mistrust for the justice community as a whole. Given these facts, it is obvious the important role that ethics plays in ensuring the effectiveness as well as the professionalism in both the disciplines of psychology and criminal justice.

Cubism :: essays research papers

Cubism (a name suggested by Henri Matisse in 1909) is a non-objective approach to painting developed originally in France by Pablo Picasso and Georges Braque around 1906. The early, "pre-Cubist" period (to 1906) is characterized by emphasizing the process of construction, of creating a pictorial rhythm, and converting the represented forms into the essential geometric shapes: the cube, the sphere, the cylinder, and the cone. Between 1909 and 1911, the analysis of human forms and still lifes (hence the name -- Analytical Cubism) led to the creation of a new stylistic system which allowed the artists to transpose the three-dimensional subjects into the flat images on the surface of the canvas. An object, seen from various points of view, could be reconstructed using particular separate "views" which overlapped and intersected. The result of such a reconstruction was a summation of separate temporal moments on the canvas. Picasso called this reorganized form the &qu ot;sum of destructions," that is, the sum of the fragmentations. Since color supposedly interferred in purely intellectual perception of the form, the Cubist palette was restricted to a narrow, almost monochromatic scale, dominated by grays and browns. A new phase in the development of the style, called Synthetic Cubism, began around 1912. In the center of the painters' attention was now the construction, not the analysis of the represented object -- in other words, creation instead of recreation. Color regained its decorative function and was no longer restricted to the naturalistic description of the form. Compositions were still static and centered, but they lost their depth and became almost abstract, although the subject was still visible in synthetic, simplified forms. The construction requirements brought about the introduction of new textures and new materials (cf. paper collages). Cubism lasted till 1920s and had a profound effect on the art of the avant-garde. Russian painters were introduced to Cubism through the works bought and displayed by wealthy patrons like Shchukin and Morozov. As they did with many other movements, the Russians interpreted and transformed Cubism in their own unique way. In particular, the Russian Cubists carried even further the abstract potential of the style. Some of the most outstanding Cubist works came from the brush of Malevich, Popova, and Udal'tsova.

High School vs College Essay

Upon attending college for a semester and a half, I have found that I enjoy being a college student more than being a high school student. In the time that i have been in college, I have seen that more freedom is allowed to students in college than in high school. Such choices as the note taking, the environment, or class selection are a few examples of how college is less restrictive than high school. Because of the educational freedom and having more control over my education, I find being a college student more enjoyable than being a high school student. In high school, the classes that students take appear to be easy. They seem easy because when a person is in high school, he/she can just brush effects off. For example, if someone does not pay attention and does not do anything for the entire class period, he/she can copy someone else’s notes and still learn the material because they have that class five days a week. Another reason high school classes give the impression of being easy is because a person can miss school/class, not get penalized, and most of the time the teacher will go over the material the student had missed. â€Å"High school is mandatory and free whereas college is voluntary and expensive. â€Å"(Information for High School Students) On the other hand in college, the classes appear to be hard. A college student cannot just brush a class off. Well, he/she can, but they will suffer from it in the long run. For instance, if someone does happen to attend class but has no intention of paying attention to the lecture, he/she is going to suffer from not being attentive and will wish he/she did pay attention because most of the time professors do not review any of the lectures or material before a test. Like high school, a college student can copy another student’s notes it may be slightly helpful, but not as much as if they had been in class and attentive. College classes are also hard because a person cannot really miss a class. In order to know what is going on and what assignments are going to be due, a student needs to attend every class if possible because he/she does not have the same class five days a week. In college, it is either two or three days a week and that is it. If someone does miss a class, it is very hard to catch up on what he/she missed. In high school, â€Å"teachers provide you with information you missed when you were absent but in college professors expect you to get from classmates any notes from classes you missed. † (The Differences High school vs College) In my opinion, missing one class in college is like missing a whole week in high school because that is how much material is covered in one class. Another topic to be compared and contrasted is note taking and teachers. in high school, the notes are given directly to the students by the teacher; spelled out and everything. Sometimes the teacher will tell the students what to write down in their notes from the textbooks that are given to them. The teacher will usually tell them what to study and wait until everyone is finished writing to continue. Similarily in college sometimes a student does get one of the professors which do tell them what to write down and do write notes on the board for them, but the notes are not as vague as in high school. On the other hand, when a professor lectures, the students have to listen carefully and write downideas that seem to be importnat to them. In college, abbreviations are a key aspect because people are not going to be able to write down the professor’s lecture word for word, so instead they take the main ideas and write them down. Teachers, both in high school and college, differ in his/her own class policies. For example, both in high school and in college, you can have one teacher that is extremely nice and will tell you what to write and study and you can also have a teacher who is not so nice and does not tell you anything and you have to kind of figure it out for yourself. The last topic in which i am going to compare and contrast is the atmosphere/environment. In highschool, a student does not really have much freedom, high school is kind of like a jail. A student has to be in class by a certain time, and if he/she is late, he/she can get in an enormous amount of trouble. For instance, if a high school walks into class five minutes late, and his/her teacher is not very nice, that student is most likely going to receive a referaal and a detention. A student in high school only has roughly two to three minutes between each class. However, in college the environment is not as strict. There is a good amount of freedom at college. There are breaks between classes anywhere from a few minutes to a few hours. During these breaks, a person does not have to stay at school. â€Å"Although there is freedom in college, likewise to high school eventhough a college student will not get a referral or detention the student’s professor does seem to get mad if a student is late consistentaly and will take a point or two off his/her participation and effort grade, if he/she happen to have one of those not so nice professor’s. â€Å"(Personal Interview) Overall, there are many similarities and differences between high school and college. I found there to be more differences in my search than similarities. I stated three subject matters but there are many more, such as, the tests, the people, the work, and so on. Being a college student now, if there was an opportunity for me to go back and relive my high school days i would, but this time i would pay much more attention because once someone gets to college it seems to be ten times harder!

Property Law- Adverse Possession Essay

Introduction To understand the comments made by Young J in Shaw v Garbutt (1996) 7 BPR 14 at 816, it is necessary to discuss the doctrine of adverse possession, it’s requirements and the history of how this law has been interpreted. Philosophy of adverse possession The basic underlying philosophy for the doctrine of adverse possession is that historically land use has been favoured over disuse. The doctrine protects ownership by barring stale claims of non-occupiers and errors in the title records. The intention is not to â€Å"reward the diligent trespasser for his wrong nor to penalise the negligent and dormant owner for sleeping upon his rights†¦Ã¢â‚¬  . At common law, the possession of land raises a prima facie presumption that the possessor is the owner, and modern cases concentrate on possession as the basis of proprietary interest. What this amounts to is that a person may acquire property without the consent of the actual titleholder if he or she possesses it long enough and meets the legal requirements. Situations may arise where a person who is not the rightful owner of land occupies the land without the permission of the rightful owner. This kind of occupation of land may be deliberate, for example by a squatter who is intentionally trespassing on the land, or it may be inadvertent, for example by a neighbouring landowner who unwittingly occupies the property. The person wrongfully dispossessed of the land has a right to bring proceedings against the occupier to recover the land. However, in certain circumstances, limitation law operates after a period of time to deny the rightful owner the opportunity to bring such an action. When this happens, the occupier is able to continue in occupation undisturbed except by anyone who can prove a better legal right to possession of the land. To seek a title by adverse possession, both the satisfaction of the common law requirements in relation to adverse possession and expiration of the relevant limitation period must be established. Requirements of an adverse possessor The Real Property Act 1900 s 45D (1)(b) provides that a person in possession of land may apply at any time to the Registrar General to be recorded as the registered proprietor of the land if: â€Å"the title of the registered proprietor of an estate or interest in the land would, at or before that time, have been extinguished as against the person so in possession had the statutes of limitation in force at that time and any earlier time applied, while in force, in respect of that land†. In NSW the current legislation on limitation of actions is governed by the Limitation Act 1969. S.27(2) of the Act states that the limitation period for an action to recover land is 12 years. S 45D(4) of the Act prevents the lodgement of a possessory application unless the whole of the period of adverse possession (in this case, twelve years) is expired. S.28 of the Act provides that the cause of any action accrues on the date of dispossession or discontinuance. To dispossess a rightful owner of land, actual possession of land without notice must exist. Actual possession consists of the following two elements: *factual possession – the appropriate degree of exclusive physical control of the land in question; and *animus possidendi – an intention to possess that land to the exclusion of all others including the true owner. One without the other will not be sufficient. To amount to adverse possession  the acts of possession must be inconsistent with the documentary owners intended use. In Beever v Spaceline Engineering Pty Ltd (1993) 6 BPR 13,270, 13,283, Bryson, J stated possession must be â€Å"actual, open, visible, notorious, continuous and hostile to the title of the true owner† to exist. In Mulcahy v Curramore [1974] 2 NSWLR 464, however, Bowen, CJ stated that to amount to possession the inclusion of the requirements â€Å"peaceful, not by force† must exist. In analysing this, Young J in Shaw v Garbutt posed the question â€Å"Is it a requirement that adverse possession be â€Å"peaceful, not by force†.† Adverse possession – inclusion of peaceful and not by force requirements Young J carefully considered the above judgment of Bowen CJ in Mulcahy v Curramore in light of the particular circumstances of Shaw v Garbutt and closely researched the definition of â€Å"peaceable† at common law. He did this in two ways; firstly he considered other judges definition of â€Å"peaceable† (including internationally); and secondly, he considered how precedence within Australia dealt with the interpretation of an aggressive act to protect one’s property whilst in adverse possession. Young, J detailed the literal translation of words used by Bowen, CJ to be â€Å"without force, without stealth, and as of right† . The Statute of Forcible Entry 1381 provides that entry into any lands except where entry is given by law must be peaceable and easy in manner. Contrary to this, is punishable by imprisonment. In Australia, the modern equivalent replacements provide ‘that it is lawful for a person in peaceable possession of land with a claim of right to use such force as he or she reasonably believes to be necessary to defend his or her possession against any person whether entitled by law to possession of the property or not, provided bodily harm is no caused†. Despite this offence of forcible entry, it was found in Hemmings v Stoke Poges Golf Club Ltd [1920] 1 KB 720 that † a person retaining possession of land has no civil action for damages against the rightful owner who forcibly enters the premises unless more force is used than is reasonably necessary†. The bench further observed that â€Å"it will still remain the law that a person who replies to a claim for trespass and assault that he ejected a trespasser on his property with no more force than was necessary may be successfully met by the reply that he used more force than was necessary if the jury can be induced to find it.† In Shaw v Garbutt many authorities are cited with varying interpretations of peaceable possession. Generally peaceable possession is seen as possession that is continuous and is not interrupted. That is it is equated not with the use of force or threats to defend possession of the land or disturbed by the commencement of a suit for possession. Clearly where violent and unlawful force is used in defending land criminal action can be pursued. Whether the possessor has been peaceable or not is a pure question of fact. Forcible or threatening conduct in warning people off property can be characterised as an act going to establish possession of the land. In Beever v Spaceline Engineering Pty Limited, the person in possession warned other persons off land by threatening with a shotgun. This was held to be â€Å"very unsatisfactory behaviour† however it was â€Å"an act of possession, in that it asserted a right to control the presence of the other person† . Young J in Shaw v Garbut t also stated that if the ‘warning off’ of the property was found to not be ‘peaceful’ at common law, the outcome of the case could have been different. In Bartlett v Ryan [2000] NSWSC 807 (16 August 2000) the specific facts of  the circumstances were considered and in this case the acts of force were determined such that the plaintiff was â€Å"deprived of the benefit of their adverse possession because it could not be said to have been nec vi nec clam nec precario, and particularly that it could not be said that it was peaceably and not by force that they had obtained and maintained possession† . As unlawful force was found an injunction was granted. Conclusion I return to the philosophy of the doctrine of adverse possession, which is fundamentally to protect property rights. The intention is not to encourage the wrongful taking of possession of land. To do so would only promote violent and unlawful acts, which would naturally occur between the parties disputing ownership of land. A person’s right to acquire real property by adverse possession begins with the wrongful occupation of another person’s property. In the event that an action is made to recover the possession of land by the rightful owner gives a circumstance where each party can exercise the rights to possession of that land. Whilst possession must be considered in every case with reference to the peculiar circumstances it is a requirement that all acts of possession be peaceable and without force, where peaceable infers uninterrupted and without force infers without violence. Protests and argument may not prevent the finding of adverse possession but obstruction and the use of unlawful physical force would.