What Is So Fascinating About Humanities 1101 Essay Samples?

What Is So Fascinating About Humanities 1101 Essay Samples? Ideas, Formulas and Shortcuts for Humanities 1101 Essay Samples All essays will have a particular topic that's either one you choose or one which is provided for you. Our aim is to supply you with a professionally written essay on this issue you require. There's several essays completed by them. If you're an extremely talented writer, you might be able to intuitively create a compelling essay including all the components necessary to be both persuasive and simple to swallowor follow. You may realize that while searching for one specific book you will stumble upon a number of other helpful books on exactly the same subject. Your reader will surely want to be aware of the context of your quotation or paraphrase. Readers of your essay will search for an argument that's clearly expressed in a logical purchase. You should find the proper resources for your essay and patience when finding the correct inspiration to write. It's helpful to really go through the physical procedure of writing out two or three vital questions which you want to concentrate on. With our humanities assignment assistance, you can accomplish your coveted dream. It help will be your first step towards success. Humanities 1101 Essay Samples Secrets The price generally varies based on the essay type. Its cost can hamper the attribute of the content produced. Because the exam is quite broad in its coverage, it's unlikely that any 1 person will be well informed about all of the fields it covers. Summary Hiring a low-cost essay service may be suitable pick for students at one time crunch. Therefore, it's crucial that the constant developments in technology be checked to make sure the fundamental characteristics of human nature aren't compromised. Furthermore, the sacred readings stopped being the sole guide to truth. ALL details which you derive from a secondary source has to be noted. Deciding upon a topic that's broad-based and covers many things might seem pretty tempting. however, it can lead you astray connected to the caliber of the essay that you want to submit and the effort you must put into it. The Key to Successful Humanities 1101 Essay Samples Writing a high school essay if you've got the tips about how to do essay effectively. Such last-minute searching never becomes futile, which causes unfinished essay assignments and ends in a poor grade. Today, there are lots of on-line sites which provide sample papers. Browsing for the proper sources from books and journals is vital. You can readily locate essay writing services which could write for you at cheap prices. Employing reliable sources for research is vital. The thesis statement is going to be the middle of your paper. If you begin with a narrow focus, you could always expand the reach of your topic later in the paper. Details of Humanities 1101 Essay Samples For instance, the author addresses the manner that American history classes don't typically address about the Vietnam War, despite the fact that it happened just a limited time ago. Humanities encompasses a wide variety of areas which can be applied to our day-to-day existence and boost our interpersonal interactions, it's consequently important that the humanities remain an essential part of somebody's educational experience. The humanities provide us with numerous intellectual and emotional skills that we require to have as a way to operate in our society. They are basically the study of the different ways in which people from different parts of the world and during different periods of history have processed and documented the human experience. The Uni Tutor is quite much conscious of the challenges that students want to bear while learning how to compose a humanities essay. With the increase in applications, however, you will require a stellar humanities Statement of Purpose. The College Board does not have any control over their content and can't vouch for accuracy. Technology has played a main role in the progression of deconstuctivist architectural methodologies. Don't be alarmed if you discover yourself midway via your paper and wanting to modify your thesis statement. The thesis statement could be written to attempt to convince the reader of a particular issue or point of view. It should come at the beginning of the paper. If your thesis statement is too easy, obvious, or vague, then you have to work on it a bit more.

Writing Good Persuasive Essays For Middle School Students

Writing Good Persuasive Essays For Middle School StudentsWhen writing persuasive essays, there are certain key topic areas that are likely to be found among the middle school students. You will want to be sure that you write about these topics so that you can provide the most effective argument when you get your thesis out there.You may find that the topic of human nature is something that you are going to want to consider. Even though many teachers do not think that this topic is important in persuasive essay topics for middle school students, it is important to the success of your writing skills. This is a topic that is going to help you understand what makes a person tick, as well as the techniques they use to influence others. When you are able to understand human nature and what motivates people, you will be able to use this knowledge to be more effective in persuasive essay topics for middle school students.Socialization is another important topic to discuss in persuasive essay topics for middle school students. By getting a better understanding of how kids learn at a young age, you will be able to know more about socialization and how to incorporate it into your own learning. By following the basic learning principles of basic subjects like math, social studies, and reading, you will be able to easily create persuasive essays. Once you have mastered the basics, you will be able to adapt the concepts that you learned to other topics in your writing.Another topic that should be considered when writing persuasive essays is the social group that you are dealing with. By studying the socialization of students, you will be able to gain a better understanding of how the student population is doing at your school. This is an important point to consider as many students tend to be different in their thinking and in their values. If you find that some students are highly social, you may want to consider adding some of those ideas to your essay.Besides discussing t he social groups in middle school, you should also think about one of the most important topics that a persuasive essay must deal with. This topic should be developed into the center of your essay and should not be left out. You should also be able to demonstrate how your belief aligns with what the audience thinks or believes. This is another key topic that will help to ensure that your essay is not being dismissed as being totally incorrect.In addition to considering what socialization is and how it relates to persuasive essay topics for middle school students, you should also be sure that you take the time to talk about the family structure. This will help to provide your audience with a sense of what it feels like to be a student in middle school. This is also an area that should be included in the middle school essay topic, as this is also an area where you can learn about a wide range of things.One of the best parts of writing persuasive essays is that you will be able to pres ent your ideas in such a way that you can be understood by readers. While you may think that you know the thoughts and ideas that you are going to be writing about, your reader will still have a hard time understanding you if you do not think that you understand the topic well. By including key messages along with your essay, you will be able to convince your reader that what you are saying is true and that your audience will be able to make an informed decision on whether or not they are agreeing with your essay.By taking the time to write persuasive essays, you will be able to convince others that what you are saying is true. By looking into the topics that middle school students are likely to have the most interest in, you will be able to build an excellent argument for your subject.

What Is The Name Of The Online Paper Resource For College Papers?

What Is The Name Of The Online Paper Resource For College Papers?What is the name of the paper online resource for college papers? The paper online resource for college papers is a website that contains all types of college paper resources. This website can be accessed from any place and anytime. Some other good features that you get from this website are:All of these are specially designed to help you in every possible way. They contain the latest news, information, and tips in helping you write better papers. They also contain helpful tools to help you write an essay. This website also offers helpful hints and tips for you to make your writing easier. It also helps to increase your writing speed and to eliminate errors.Researching and gathering all the data and facts that you need before writing an essay is not easy. It requires a lot of time, effort, and dedication. So if you have to complete an essay as fast as possible, the paper online resource for college papers is a must for you.In order to reduce the time needed for doing research, it is advised to go through the tips provided by the website. These tips will guide you to go through the entire process of researching and gathering the information needed to prepare your essay.As the name says, these websites do all the research and gather the information that you need to write an essay. It also allows you to learn how to draft an essay in a specific way that suits your style and the style of your audience. It gives all the tips needed to help you in writing an essay in a correct and concise manner. It also helps you learn different strategies to improve your essay writing.It is advised to choose the best paper online resource for college papers to save time and effort. You can also use this resource to help you find the right type of essay topic and the best essay writing style. You will surely benefit from it as it helps you in writing a convincing essay in a much faster and organized manner.These tips a nd suggestions from the paper online resource for college papers will be able to provide you all the necessary resources to write your essay successfully. It will also provide all the tips and hints that you will need to enhance your own knowledge and skills to help you in making a good essay.

Sample Outline For Narrative Essay

Sample Outline For Narrative EssayAn outline for a narrative essay will help you keep everything in writing. It is like a map that you can follow in order to get to the destination. The key is to follow it properly and write in a way that it can be understood by your readers.First of all, you need to establish your purpose. Explain why you are writing about a particular subject. Tell them the reason why you want to know the truth behind what has been happening.The next step is to select a broad topic. The topic should not be too broad. You need to define it first before proceeding to write the narrative. A topic can be any subject. It may be a political issue, a historical event, an art form, or a social institution.The next step is to decide on the main character of the narrative. It is also known as the hero. The hero will be the protagonist of the story. The hero should be well developed so that readers are attracted to his story. A well-developed character is like a jewel that wi ll attract people's attention.A literary device is also needed in a narrative. A literary device is a word, phrase, or idea that conveys a particular meaning. In writing the narrative, this literary device is also called a theme. The literary device is usually very important. The writer must be able to establish the theme at the beginning of the story so that readers will know what they need to do in order to follow the narrative.The next step is to plot the main character. There are many ways to plot a character, but in this case, you can use the story arc. Story arcs are the common way to follow. You can make use of a novel timeline or to follow a guide.The characters that you have established in the story arc should now have a purpose. You need to ask yourself, why should the character do this? You need to keep in mind that what is the story about?Now that you know the outline for a narrative essay, you are well on your way to complete your story. You will have to follow the step s to achieve your purpose. Take your time to get your story right and you will end up with a gripping tale that will keep readers' attention. Keep in mind that writing a narrative essay is a lot more than just writing.

Short Responses on Several Books Similarities in Family Values

The working poor: Invisible in America By David Shipler Introduction America is a developed country but there still exists a group of people called the working poor. Although these people are working, they still languish in poverty. They live between a state of â€Å"poverty† and â€Å"well being†. Their efforts to move from â€Å"poverty bracket† to â€Å"well being bracket† are diminished due to negligence by the government. This book focuses on American working poor and what the government is doing to help the situation.Advertising We will write a custom report sample on Short Responses on Several Books Similarities in Family Values specifically for you for only $16.05 $11/page Learn More Summary The author writes about the group of individuals struggling to survive in the US. His focus is on the people who are working but struggling to live and meet their daily needs. He terms them as people who have been left behind. Exis tence of such groups of people at a time when the US is celebrating its prosperity is considered a disgrace. The author carries out several interviews with people who are struggling to meet their basic needs like medical care. He finds out that most of these people are working and some are even engaged in full time jobs. He is not pleased with the kind of life these people are leading despite their hard work. He believes that the government is not doing much to address the issue of the working poor. He adds that the government is not implementing laws that can help the working poor improve their living standards. Although there are laws set up to protect the working poor, the process of implementing them is very poor and this leads to their failure. The kind of leadership in place can not come up with strategies to ensure that the laws are enforced. Therefore, it is very difficult to change the situation. This book also reveals many other facts about the life of the working poor. Al l these facts give an indication of failure of leadership at state as well as national level. This means that the economic prosperity can not be sustained. The author suggests various ways by which the working poor can be helped. He insists that the government and the private sector should work hand in hand with other agents to come up with collective strategies that will improve the living standards of the working poor. In order to help the working poor, the author proposes wage reform strategy that will regulate employers on how they pay their workers. He also says that the wage reform should apply at the bottom as well as the top. It should be able to set the minimum as well as the maximum pay standards for the workers for equality purposes. The issue of excess wealth to some Americans should be considered. Some Americans are paid very high salaries leading to various imbalances and creating a huge gap between the poor and the rich. The book ends by the author appealing for ideol ogical debate. He says that unless the ideological debate is encouraged and incorporated in public policies, the situation of the working poor is likely to remain the same. He says that it is time to table the facts about the working poor so that proper steps can be taken to correct the situation. Silence means prolonging the problem but not solving the problem.[1]Advertising Looking for report on american literature? Let's see if we can help you! Get your first paper with 15% OFF Learn More The central theme The main theme featured in this book is poverty. The author examines a group of Americans who are completely left behind despite their hard work. He refers to them as the working poor. Although these groups of people are working, their living standards are still low. Despite their effort and willingness to work hard, it is almost impossible for them to attain their American dream. In case of a financial obstacle, the working poor may not be able survive and this m ay lead to an irreversible financial downfall. They live up to their means with no funds left for emergency cases. In this book, the author holds various conversations with the working poor. He finds out that the working poor are held in dead end jobs where chances for advancement and improvement are very slim. There are no benefits and opportunities for further development. These are the factors that make the working poor languish in poverty. The author also blames the government systems that are set up to help the working poor. He says that most of these systems are only provided but not implemented. Their effects are not visible at all. Some of the working poor are also resistant to help from the systems. Others are completely unaware that there are such systems in place to help them.[2] The quantitative role played by the US The United States as a cultural entity is not very aware of the factors that contribute to poverty. This means that the US is not so sure of the solutions t hat might fully correct this situation. However, there are many ways in which US play a role concerning the invisible working poor. Politically, the government has come up with laws that enforce minimum wage. The only problem is that these laws are not implemented according to the government specifications leading to their failure. In fact the working poor are being charged high bills when it comes to health care and other public services. This raises their expenditures with no increase in income leading to poverty. Although there are many upcoming ways to help the working poor, the author insists that no single way can succeed in correcting this situation. He proposes that the government should work hand in hand with the private sector to ensure that the laws are well implemented. Among the strategies proposed include changing of the present wage structure, fair distribution of public resources and coming up with programs that are more vocational. The perception of the US in the bo ok I think the perception of the US in this book is negative. Although US is considered as a land of opportunities, there still exists a group of people who are working but still live in poverty. These people have been neglected and their welfare is not a priority anymore to America.Advertising We will write a custom report sample on Short Responses on Several Books Similarities in Family Values specifically for you for only $16.05 $11/page Learn More This is because the laws that have been put in place to help these people are not enforced into actions. The government is not committed to evaluate its law system to make sure that the laws are being obeyed. This shows how the US is less concerned with the working poor. We are told that the working poor are handled like slaves despite the existence of laws that enforce humane working conditions and minimum wage. As much as we expect the working poor people to be treated at low medical costs in hospitals, they are being charged much more money than they can afford. Any emergency treatments, transport and other medical costs are even worsening the situation of the working poor.[3] Lessons that the book holds for US citizens There are very many lessons that this book holds for the US citizens. First, the US citizens need to be very careful when choosing leaders in future. They need to elect leaders who will implement the set laws and make sure that the laws are obeyed. This will reduce poverty among the working poor. The US citizens need to learn that despite being a developed country, there are still groups of people who are languishing in poverty. With this in mind, they can be able to strategize on the factors contributing to this situation and come up with viable solutions that can help correct the situation.[4] How to change the problems addressed in the book From a personal perspective, I would encourage formation of movements and unions that will protect and fight for the rights of the working poor. These unions and movements will be able to push for reforms and law implementations that will see the working poor improve. From a perspective of US policy, the government needs to make sure that those laws concerning minimum wage and humane working conditions are enforced and implemented. This is through setting up of law structures and arms that will monitor the implementation process and ensure that everybody is obeying the laws.[5] Conclusion Poverty is an urgent issue in the American society especially among the working poor. These issue need to be addressed by the government in collaboration with other agents for improvement of the living standards of the working poor.Advertising Looking for report on american literature? Let's see if we can help you! Get your first paper with 15% OFF Learn More Reference List Both, Deborah and Barbara. Zang. 2009. The working poor in America. Washington, DC: National academy press. Shipler, David. 2004. The working poor: Invisible in America. New York: Knopf publishers. Footnotes David Shipler, The working poor: Invisible in America (New York: Knopf publishers 2004), 21. Ibid, 23. Ibid, 23. Ibid, 23. Deborah Both and Barbara Zang,The working poor in America (Washington, DC: National academy press 2009), 54. This report on Short Responses on Several Books Similarities in Family Values was written and submitted by user Edison Clarke to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

Achievements of India in Space Research Essay Example

Achievements of India in Space Research Essay Example Achievements of India in Space Research Essay Achievements of India in Space Research Essay The Indian space program began establishing itself with the launch of sounding rockets, which was complimented by Indias geographical proximity to the equator. These were launched from the newly-established ThumbaEquatorial Rocket Launching Station (TERLS) , built near Thiruvananthapuram in southern Kerala. Initially, American sounding rockets like the Nike-Apache, and French sounding rockets like the Centaure, were fired and used for studying the upper atmospheric electrojet, which until then had only been studied from ship-based sounding rocket launches in the Pacific Ocean. These were soon followed by British and Russian rockets. However, since day one, the space program had grand ambitions of developing indigenous technology and India soon began developing its own sounding rockets, using solid propellants -these were called the Rohini family of sounding rockets. As the Indian Rohini program continued to launch sounding rockets of greater size and complexity, the space program was expanded and eventuallygiven its own government department, separate from the Department of Atomic Energy. In 1969 the Indian Space Research Organization(ISRO) was created from the Indian National Committee for Space Research (INCOSPAR) program under the DAE, continued under the Space Commission and finally the Department of Space, created in June of 1972. (1970-1980) In the 1960s, Sarabhai had taken part in an early study with NASA regarding the feasibility of using satellites for applications as wide as direct television broadcasting, and this study had found that it was the most economical way of transmitting such broadcasts. Having recognized the benefits that satellites could bring to India from the very start, Sarabhai and the ISRO set about designing and creating an independent launch vehicle, capable of launching into orbit, and providing the valuable experience needed for the construction of larger launch vehicles in future. Recognizing the advanced capability India had in building solid motors with the Rohini series, and that other nations had favoredsolid rockets for similar projects, the ISRO set about building the technology and infrastructure for the Satellite Launch Vehicle (SLV) . Inspired by the American Scout rocket, the vehicle would be a four-stage all-solid vehicle. Meanwhile, India also began developing satellite technology, anticipating the remote sensing and communication needs of the future. Indias first foray into space began with the launch of its satellite Aryabhata in 1975 by a Soviet booster. By 1979, the SLV was ready to be launched from a newly-established second launch site, the Shriharikota Rocket Launching Station (SRLS) . The first launch in 1979 was a failure, attributed to a control failure in the second stage. By 1980 this problem had been worked out. The first indigenous satellite launched by India was called Rohini-1 . (1980-1990)Following the success of the SLV, ISRO was keen to begin construction of a satellite launch vehicle that would be able to put truly useful satellites into polar orbits. Design of the Polar Satellite Launch Vehicle (PSLV) was soon underway. This vehicle would be designed as Indias workhorse launch system, taking advantage of both old technology with large reliable solid-stages, and new liquid engines. At the same time, it was decided by the ISRO management that it would be prudent to develop a smaller rocket, based on the SLV thatwould serve as a testbed for many of the new technologies that would be used on the PSLV. The Augmented Satellite Launch Vehicle (ASLV) would test technologies like strap-on boosters and new guidance systems, so that experience could be gained before the PSLV went into full production. Eventually, the ASLV was flight tested in 1987, but this launch was a failure. After minor corrections, another launch was attempted in 1988, this launch again failed. 1990-2000)It was not until 1992 that the first successful launch of the ASLV took place. At this point the launch vehicle, which could only put very small payloads into orbit, had achieved its objective. In 1993, the time had come for the maiden flight of the PSLV. The first launch was a failure. The first successful launch took place in 1994, and since then, the PSLV has become the workhorse launch vehicle - placing both remote sensing and communications satellites into orbit, creating the largest cluster in the world, and providing unique data to Indian industry and agriculture. Continual performance upgrades have increased the payload capacity of the rocket significantly since then. By this time,with the launch of the PSLV not far away, it had been decided that work should begin on the next class of launch vehicles, intended to place larger satellites into geostationary transfer orbit (GTO), and thus a launcher partly derived from the PSLV design, but featuring large liquid strap-on motors and a cryogenic upper-stage motor, was devised -the Geostationary Satellite Launch Vehicle. 2000)Major achievement which seems to have gone largely unnoticed is ISRO’s successful ground testing of the cryogenic engine on November 15, 2007. This test - conducted for its full flight duration of 720 seconds at the Liquid Propulsion test facility at Mahendragiri, Tamil Nadu, puts India on the world map of cutting edge rocket propulsion technology. Only five other nations - The US, Russia, Japan, China and France - currently have this capability. Cryogenicengines are im portant for launch of satellites, particularly of the INSAT variety which operate from a geostationary orbit, some 36,000 km above earth’s surface. To launch these, ISRO uses a vehicle called GSLV (Geosynchronous Satellite Launch Vehicle). This vehicle has three stages of which the third - and the most critical - stage is a cryogenic stage Sofar, India uses a Russian-made cryogenic engine. But with this recent test, the decks are cleared for using an indigenous engine for the next GSLV (GSLV-D3) launch, expected in 2008. Cryogenics studies behavior of materials at very low temperatures - below minus 150 ° Celsius (minus 238 ° Fahrenheit or 123 ° Kelvin) - as found in the upper atmosphere. The cryogenic engine, which uses a combination of liquid hydrogen and liquid oxygen as fuel, needs to run forover 700 seconds for GSLV launches. Space Capsule Recovery Experiment The Space Capsule Recovery Experiment (SRE-1) is an Indian experimental spacecraft which was launched at 03:53 GMT on January 10, 2007 from Shriharikota by the Indian Space Research Organization (ISRO). The launch was conducted using the PSLV C7 rocket, along with three other satellites. It remained in orbit for 12 days before re-entering the Earths atmosphere and splashing down into the Bay of Bengal at 04:16 GMT on January 22. The SRE 1 was designed to demonstrate the capability to recover an orbiting space capsule, and the technology of an orbiting platform for performing experiments in microgravity conditions. It was also intended to test reusable Thermal Protection System, navigation, guidance and control, hypersonic aero-thermodynamics, management of communication blackout, deceleration and flotation system and recovery operations. Chandrayaan-1 First mission to the Moon launched by Indias national space agency the Indian Space Research Organization (ISRO). The unmanned lunar exploration mission includes a lunar orbiter and an impactor. India launched the spacecraft by a modified version of the PSLV C11 on 22 October 2008 from Satish Dhawan Space Centre, Shriharikota, Nellore District, Andhra Pradesh about 80 km north of Chennai at 06:22 IST (00:52 UTC). The mission is a major boost to Indias space program, as India joins Asian nations China and Japan in exploring the Moon. The vehicle was successfully inserted into lunar orbit on8 November 2008. On November 14, 2008, the Moon Impact Probe separated from the Moon-orbiting Chandrayaan at 20:06 and impacted the lunar South Pole in a controlled manner, making India the fourth country to place its flag on the Moon. The MIP impacted near the crater Shackleton, at the lunar south pole, at 20:31 on 14 November 2008 releasing subsurface debris that could be analyzed for presence of water ice. The estimated cost for the project is Rs. 386 crore (US$ 80 million). The remote sensing lunar satellite had a weight of 1,380 kilograms (3,042 lb) at launch and 675 kilograms (1,488 lb) in lunar orbit and carries high resolution remote sensing equipment for visible, near infrared, and soft and hard X-ray frequencies. Over a two-year period, it is intended to survey the lunar surface to produce a complete map of its chemical characteristics and 3-dimensional topography. The Polar Regions are of special interest, as they might contain ice. The lunar mission carries five ISRO payloads and six payloads from other international space agencies including NASA, ESA, and the Bulgarian Aerospace Agency, which were carried free of cost. Objectives The stated scientific objectives of the mission are: To design, develop, launch and orbit a spacecraft around the Moonusing an Indian-made launch vehicle. Conduct scientific experiments using instruments on-board the spacecraft which will yield the following results: Preparation of a three-dimensional atlas (with high spatial and altitude resolution of 5-10 m) of both the near and far side of the Moon. Chemical and mineralogical mapping of the entire lunar surface at high spatial resolution, mapping particularly the chemical elements Magnesium, Aluminium, Silic on, Calcium, Iron, Titanium, Radon, Uranium, Thorium. The impact of a sub-satellite (Moon Impact Probe - MIP) on the surface on the Moon as a fore-runner to future soft-landing missions. Specifications Mass:1380 kg at launch, 675 kg at lunar orbit, and 523 kg after releasing the impactor. Dimensions: Cuboid in shape of approximately 1. 5 m Communications: X band, 0. 7 m diameter parabolic antenna for payload data transmission. The Telemetry, Tracking Command (TTC) communication operates in S band frequency. Power: The spacecraft is mainly powered by its solar array, which includes one solar panel covering a total area of 2. 15 x 1. 8 m generating 700 W of power, which is stored in a 36 A ·h lithium-ion battery. The spacecraft uses a bipropellant integrated propulsion system to reach lunar orbit as well as orbit and altitude maintenance while orbiting the Moon. Specific areas of study High-resolution mineralogical and chemical imaging of the permanently shadowed north and south polar regions. Search for surface or sub-surface water-ice on the Moon, especially at thelunar poles. Identification of chemicals in lunar highland rocks. Chemical stratigraphy of lunar crust by remote sensing of the central uplands of large lunar craters, and of the South Pole Aitkin Region (SPAR), where interior material may be expected. Tomap the height variation of the lunar surface features. Observation of X-ray spectrum greater than 10 keV and stereographic coverage of most of the Moons surface with 5 m resolution To provide new insights in understanding the Moons origin and evolution. Payloads:  ®TMC or the Terrain Mapping Camera,  ®HySI or Hyper Spectral Imager,  ®LLRI or Lunar Laser Ranging Instr ument,  ®C1XS or X-ray fluorescence spectrometer,  ®HEX is a High Energy X-ray/gamma ray spectrometer, ®MIP or the Moon Impact Probe Major achievements 1962:Indian National Committee for Space Research (INCOSPAR); formed by the Department of Atomic Energy, and work on establishing Thumba Equatorial Rocket Launching Station (TERLS) near Trivandrum began. 1963: First sounding rocket launched from TERLS on November 21, 1963. 1965: Space Science Technology Centre (SSTC) established in Thumba. 1967: Satellite Telecommunication Earth Station set up at Ahmadabad. 1972: Space Commission and Department of Space set up. 1975: First Indian Satellite, Aryabhata, launched (April 19, 1975). 1976: Satellite Instructional Television Experiment (SITE) conducted. 1979: Bhaskara-1, an experimental satellite launched. First experimental launch of SLV-3 with Rohini satellite on board failed. 1980: Second experimental launch of SLV-3 Rohini satellite successfully placed in orbit. 1981: APPLE, an experimental geostationary communication satellite successfully launched on June 19. 1981: Bhaskara-II launched on November 20. 1982: INSAT-1A launched (April); deactivated in September. 1983: Second launch of SLV-3. RS-D2 placed in orbit. INSAT-1B launched. 1984: Indo-Soviet manned space mission (April). Rakesh Sharma became the first Indian to reach space. 1987: ASLV with SROSS-1 satellite on board launched. 1988: First Indian remote sensing satellite, IRS-1A launched. INSAT-1C launched (July). Abandoned in November. 1990: INSAT-1D launched successfully. 1991: Launch of second operational Remote Sensing satellite, IRS-1B (August). 1992: Third developmental launch ofASLV with SROCC-C on board (May). Satellite placed in orbit. First indigenously built satellite INSAT-2A launched successfully. 1993: INSAT-2B launched in July successfully. First developmental launch of PSLV with IRS-1E on board fails. 1994: Fourth developmental launch of ASLV successful (May). Second developmental launch of Polar Satellite Launch Vehicle (PSLV) with IRS-P2 successfully (October). 1995: INSAT-2C launched in December. Third operational IRS (IRS) launched. 1996: Third developmental launch of PSLV with IRS-P3 successful (March). 1997: INSAT-2D launched in June became inoperational in October. Arabsat1C, since renamed INSAT-2DT, acquired in November. First operational launch of PSLV with IRS-1D successful (September). 1998: INSAT system capacity augmented with the readiness of INSAT-2DT acquired from Arabsat (January). 1999: INSAT-2E the last satellite in the multi-purpose INSAT-2 series, launched by Ariane from Kourou French Guyana (April 3, 1999). IRS-P4 (OCEANSAT), launched by Polar Satellite launch vehicle (PSLV-C2) along with Korean KITSAT-3 and German DLR-TUBSAT from Shriharikota(26 May 1999). 2000: INSAT-3B was launched on 22 M arch 2000. 2001: Geosynchronous Satellite Launch Vehicle-D1 (GSLV-D1), the first developmental launch of GSLV with GSAT-1 onboard partially successful. 2002: INSAT-3C launched successfully by Arianespace (January), PSLV-C4 launches KALPANA-1 (September). 2003: GSLV-D2, the second developmental launch of GSLV with GSAT-2 successful (May). 2004: First operational flight of GSLV (F01) successfully launches EDUSAT (September). 2005: Launch of CARTOSAT and HAMSAT by PSLV-C6 from the second launch pad (Universal Launch Pad) (May). INSAT 4A Launched successfully by the European Ariane-5G. 2006: Second operational flight of GSLV (F02) unsuccessful July 10, 2006. GSLV-F02 was carrying INSAT-4C. 2007: Successful launch of CARTOSAT-2, SRE-1, LAPAN-TUBSAT and PEHUENSAT-1 on PSLV C7 on January 10, 2007. 2007: SRE-1 splashed down in the Bay of Bengal on January 22, 2007 and was successfully recovered by the Indian Coast Guard and Indian Navy, making India one of the few countries to have re-entry technology. 2007: INSAT-4B successfully launched by Arianespace on March 12. 2007: PSLV-C8 successfully places an Italian satellite, AGILE into its orbit on April 23. 2007:Successful launch of GSLV (GSLV-F04) with INSAT-4CR on board from SDSC SHAR on September 2. 2008: PSLV-C10 successfully launches TECSAR satellite under a commercial contract with AntrixCorporation on January 21. 2008:PSLV-C9 successfully launches CARTOSAT-2A, IMS-1 and 8 foreign nanosatellites from Shriharikota on April 28 2008:PSLV-C11 successfully launches CHANDRAYAAN-1 fromSriharikota on October 22. Satellite Launch Vehicles Satellite Launch Vehicle (SLV) -an all-solid four-stage satellite launch vehicle. The SLV can place 40 kg into low earth orbit. Augmented Satellite Launch Vehicle (ASLV) -an all-solid five-stage satellite launch vehicle. The ASLV can place 150 kg into low earth orbit. Present Polar Satellite Launch Vehicle (PSLV) -a four-stage rocket with liquid and solid stages. The PSLV can place 1600 kg into polar sun synchronous orbit. Geosynchronous Satellite Launch Vehicle Mark I/II (GSLV-I/II) -a three-stage rocket with solid, liquid and cryostages. The GSLV can place 2200 kg into geostationary transfer orbit. Future Geosynchronous Satellite Launch Vehicle Mark III (GSLV-III) -a three-stage rocket with solid, liquid and cryostages. The GSLV can place 4000-6000 kg into geostationary transfer orbit. Reusable Launch Vehicle (RLV) -a small remote-piloted scramjet vehicle called AVATAR. The RLV will place small satellites into LEO and can be reused for at least 100 launches reducing the cost of launching satellites Launch facilities ISRO operates 3 launch stations: Thumba (TERLS -Thumba Equatorial Rocket Launching Station/Vikram Sarabhai Space Center, Kerala) Shriharikota (SRLS -Shriharikota Rocket Launching Station/Satish Dhawan Space Center, Andhra Pradesh). Balasore (BRLS -Balasore RocketLaunching Station, Orissa). The Shriharikota range is used for launch of satellites and multi-stage rockets. The launch station has two launch pads including the newest Universal Launch Pad. The two launch pads allow the station to hold up to 6 launches per year. The other two launch facilities are capable of launching sounding rockets, and other small rockets that dont produce spent stages. Comparison with other space agencies It is suggested that in terms of technical expertise and experience, ISRO is close to other major Asian space programs, especially China, and in some respects to Japan. Continued development of reliable and cost-effective launch platforms are expected to see commercial costs of launching payloads on Indian rockets fall, perhaps by as much as fifty percent. Once established, the Indian GSLV-III should be able to place 4000 to 6000 kg payloads into GTO Despite ISROs modest funding, it appears to have achieved reasonable successes . India is counted amongst the six major space powersof the world, and is among the top nations in Asia in terms of success and future potential in space. Indian launch vehicles have the capacity for human spaceflight, however, ISRO has stated that it can achieve all Indias commercial and scientific needs through unmanned spaceflight alone, raising the question of whether a crewed spaceflight will occur.

Although the foetus has no right to life, its interests are adequately protected by English law.

There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. Principles of Medical Law, OUP Oxford, 3rd Edition, (2010). Jackson, E. Medical Law: Text, Cases and Materials (Text, Cases and Materials), OUP Oxford, 2nd Edition, (2009). Mason, K. and Laurie, G. Mason and McCall Smith’s Law and Medical Ethics, OUP Oxford, 8th Edition, (2010). Articles: Abortion Rights Campaign, Why women need a modern abortion, law and better services, Available [Online] at: http://www.abortionrights.org.uk/content/view/180/121/ BBC, Women’s Rights Arguments in Favour of Abortion, Ethics Guide, (1992), Available [Online] at: http://www.bbc.co.uk/ethics/abortion/mother/for_1.shtml K.D and Gearty. CA, Terminating Abortion RightsNew Law Journal, 142 NLJ 1969, Issue 6579, (04 December, 1992). C, Forty Years On, New Law Journal, 157 NLJ 1517, Issue 7295, (02 November, 2007). Frankenburg, G., ‘Human Rights and the Belief in a Just World’ International Journal of Constitutional Law, Volume 12, Issue 1. Holetzky, S. What is Judicial Activism(04 February, 2010), Available [Online] at: http://www.wisegeek.com/what-is-judicial-activism.htm Human Rights, Right to Life: Not just an abortion issue, Available [Online] at: http://www.abouthumanrights.co.uk/right-life-not-just-abortion-issue.html I, A Vacancy in the Supreme Court, New Law Journal, 144 NLJ 537, Issue 6644, (22 April, 1994). McCrudden, C. Human Dignity and Judicial Interpretation of Human Rights, European Journal of International Law, EJIL 2008 19 (655), Issue 4, (01 September, 2008). O’Donovan, K. Commentary, Medical Law Review, Med Law Rev 2006 14 (115), (01 March, 2006). Sandel, M. J. Symposium: Law, Community, and Moral Reasoning Moral Argument and Liberal Toleration: Abortion and Homosexuality, California Law Review, 77 Calif. L. Rev. 521, (May, 1989). The Society for the Protection of Unborn Children, SPUC, Abortion and disability or eugenic abortion, Available [Online] at: http://www.spuc.org.uk/students/abortion/disability Thielen, D. Overturn Roe v Wade, Liberal and Loving It, (2005), Available [Online] at: http://www.davidthielen.info/politics/2005/08/overturn_roe_vs.html Wicks, E., Wyldes, M. and Kilby, M. Late Termination of Pregnancy for Foetal Abnormality: Medical and Legal Perspectives, Medical Law Review, Med Law Rev 2004.12 (285), (01 September, 2004). Although the foetus has no right to life, its interests are adequately protected by English law. There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. Principles of Medical Law, OUP Oxford, 3rd Edition, (2010). Jackson, E. Medical Law: Text, Cases and Materials (Text, Cases and Materials), OUP Oxford, 2nd Edition, (2009). Mason, K. and Laurie, G. Mason and McCall Smith’s Law and Medical Ethics, OUP Oxford, 8th Edition, (2010). Articles: Abortion Rights Campaign, Why women need a modern abortion, law and better services, Available [Online] at: http://www.abortionrights.org.uk/content/view/180/121/ BBC, Women’s Rights Arguments in Favour of Abortion, Ethics Guide, (1992), Available [Online] at: http://www.bbc.co.uk/ethics/abortion/mother/for_1.shtml K.D and Gearty. CA, Terminating Abortion RightsNew Law Journal, 142 NLJ 1969, Issue 6579, (04 December, 1992). C, Forty Years On, New Law Journal, 157 NLJ 1517, Issue 7295, (02 November, 2007). Frankenburg, G., ‘Human Rights and the Belief in a Just World’ International Journal of Constitutional Law, Volume 12, Issue 1. Holetzky, S. 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The Society for the Protection of Unborn Children, SPUC, Abortion and disability or eugenic abortion, Available [Online] at: http://www.spuc.org.uk/students/abortion/disability Thielen, D. Overturn Roe v Wade, Liberal and Loving It, (2005), Available [Online] at: http://www.davidthielen.info/politics/2005/08/overturn_roe_vs.html Wicks, E., Wyldes, M. and Kilby, M. Late Termination of Pregnancy for Foetal Abnormality: Medical and Legal Perspectives, Medical Law Review, Med Law Rev 2004.12 (285), (01 September, 2004).