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Fifty Plus Programs and Classes

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Home   50+  Fifty+ Classes and Programs

A variety of classes and programs are offered for 50+ including  creative arts , fitness ,  recreation , and  sports . Most programs are offered on a quarterly basis and the class schedule is published in the Fifty Forward newsletter.

Many classes are offered on a drop-in basis, and drop-in passes are available for all exercise classes.

Scholarships are available for low-income Troy residents 50 and older with an annual income of $24,450 or less for a one-person household or $27,950 or less for two persons. Receive a 25% discount, maximum one class per person per season (two computer classes per season). There is no discount for drop-in programs, trips, sport leagues, and special events. Apply at the Community Center. Last year’s federal or state form 1040 or MI Homestead form required as proof of income.

Creative Arts

*Indicates registration required 

*Anyone Can Paint
Second Thursdays, 6–8 pm

Ballroom Dance Drop-In Lessons
Mondays and Wednesdays, 1–2 pm
Drop in, pay at the door

Harmonica Club
Rehearsals on Monday at 9:30 am, September–June
Occasional performances, drop in

Heritage Concert Band
Rehearsals 1st and 3rd Wednesday at 7:30 pm
No string instruments except the string bas.

*Jewelry Making
Classes held quarterly throughout the year.
Afternoon and evening sessions.

*Piano, Guitar & Voice Lessons
Piano: Thursdays, 10:15 am
Guitar: Thursdays 11 am
Voice: Thursdays 11:45 am

*Knitting & Crocheting Lessons

Needlework Club
Tuesdays at 10 am
Drop in

Painting Club
Thursdays, 9 am
Drop in, all levels and ages welcome

*Painting Lessons

Wednesday, 7–9:30 pm

Quilting Group
Wednesdays, 9 am–4 pm
Drop in

Sewing Group
Mondays, 12–5pm
Drop in.

Square Dancing
Beginner lessons: Mondays at 7 pm
Drop in, pay at the door
Drop in dancing: Fridays, November–May, 7:30–9:30 pm  
$5 per person, payable at the door

*Swing & Ballroom Dance Lessons
Fridays, 7–10 pm

*Tap Lessons
Beginners: Tuesdays, 1:30 pm
Intermediate: Tuesdays, 2:30 pm

Woodcarving Club
Mondays, 8:30 am
All levels and ages welcome

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All classes meet at the Troy Community Center. Drop-in passes are available for all exercise classes. A $6 pass admits you to one 50-minute class ($7 for non-residents). Purchase passes at the Community Center front desk. 10 visit punch cards are also available $60/Res, $70/NR

Fitness Programs Include

  • Aquatic Exercise: Tuesday and Thursday 9 and 10 am
  • Balance & Stretch: Monday, Wednesday, Friday at 9 am.
  • Chair Exercise: Monday, Wednesday and Friday at 11 am. Drop-in. 10 visit punch card to attend is available for $16/Res and $21/NR.
  • Low Cardio, Stretch and Tone: Monday, Wednesday and Friday 8 am.
  • Muscle Strengthening: Tuesday and Thursday at 10 am
  • Yoga/Pilates: Tuesday and Thursday at 11 am
  • Pilates (beginning): Monday and Wednesday at 10 am
  • Tai-Chi: Monday afternoon – two/three levels
  • Yoga: Monday and Wednesday at 11 am
  • Yoga (Chair): Tuesday at 11 am
  • Women on Weights: Tuesday and Thursday at 6 pm
  • Zumba Gold: Tuesday and Friday at 10 am and Wednesday at 7 pm. Drop-in. Pay at door.
  • Zumba Toning: Tuesday at 10am, Drop-in, Pay at door.

Exercise has wide ranging beneficial effects on cholesterol, blood pressure, blood sugar and weight control. Indeed, exercise probably is the single most important factor to successfully living an independent, non-medicated life. Center for Preventative Medicine

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Drop in to play billiards during regular Community Center hours

A bingo game is held each Friday at the Community Center from 1–2:30 pm with cash prizes.

Several card groups meet at the Community Center including duplicate bridge, party bridge, pinochle, euchre and cribbage.

Community gardens for ages 50+ are available at the Troy Farm at Beach Road and South Blvd. Plots are approx. 20′ x 20′ and water is available. Look for details in the March/April Fifty Forward senior newsletter.

MahJong Club
Meets Wednesdays from 1–3:30pm, Fridays from 1-4pm. Drop-in.

Pacific Rim Outreach
Seniors of Asian descent meet at the Community Center on Wednesdays from 12:30–3:30 pm for social activities, information and referral and English communication activities.

Red Hat Society
The Red Mad Hatters, the Troy Chapter of the Red Hat Society, meets on the second Tuesday of each month at 1 pm for socialization and outings. Wear your red hat!

One to two one-day trips are offered each month to destinations such as the Fisher Theater, Orchestra Hall, local casinos, Frankenmuth and much more. Several extended trips are also offered each year to destinations worldwide with transportation to the airport and the services of a local tour guide included in the package. See the Fifty Forward senior newsletter for details.

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Bowling League
Mondays at 1:30 pm at Troy Lanes, 1950 E. Square Lake, September through May. Partners are not required. Receive points for beating your own average.

A Monday morning league and a Wednesday morning league play at Sylvan Glen. Men and women of all levels are welcome. The leagues are divided into three flights. See the November/December Fifty Forward senior newsletter for more information.

Seniors can play drop-in Pickleball at the Community Center on Mondays from 11:30 am-3 pm and Fridays from 10:30 am–3 pm. Special Senior Special rate of $4 for resident and non-resident seniors. Drop-in play also available for all ages 18 and over on Wed. evenings from 6–8:30 pm. Daily pass rates apply, free to fitness center members Ladder leagues offered Tuesdays 1–2:30pm (fall, winter and spring sessions), Fridays 6–8pm, and Sundays 6:15–8:15 pm. 

Four Outdoor courts now available at Redwood Park. Drop-in play Mondays and Fridays from 10 am–2 pm and an organized Sunday night Mixer from 6–8 pm beginning in early June.

Softball League
A men’s 50 Plus league plays on Thursday evenings while a women’s 50 Plus league plays other cities on Tuesday evenings. Call Scott Mercer at 248.524.3484 for details.

Tennis Leagues
An informal, outdoor league meets on Tuesday and Friday mornings May through September at the Boulan Park courts. Contact Judy Luther for more information at 248.879.9550. A Wednesday afternoon league meets indoors at the Troy Racquet Club in the fall and winter. Call 248.528.3400 for more information.

Volleyball League
Men and women 55 and older play other cities in Oakland and Macomb Counties on Tuesday mornings, November through March in Warren. Practice Monday and Thursday from 9:30–11 am at the Troy Community Center mid-September through March.

Michigan Senior Olympics
Many Troy athletes participate in the Michigan Senior Olympics each summer winning dozens of medals. See the Fifty Forward Senior Newsletter each spring for registration information or visit the  Michigan Senior Olympics website.

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How to Structure an English Literature Essay

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Writing assignment series

Essays in Literature Classes

Brainstorm the question/assignment:

  • Restate key words
    in the assignment with synonyms or
    in your own words;
  • Use these equivalent terms
    throughout your paper to
    keep focused.;
  • Write down everything
    you can think of that is
    related to the assignment;
  • Generate two or three specific sentences
    that answer a question posed by the assignment;
  • Write your introduction last,
    after you’ve had a
    chance to work your way to a conclusion;
    Often it helps to take your conclusion, use what you’ve

    and then write the introduction in the next draft.

Refine your focus:

  • After writing your initial “guiding sentence”
    (thesis statement), write a draft, then go back to the thesis
    and perhaps re-write it;
  • Include in each paragraph an explicit reference
    to the language you use in your thesis. If the paragraphs are
    not an extension of something in your thesis, either re-write your
    thesis statement, edit the paragraph, or cut it. Often you can
    revise the paragraph by adding words that more explicitly make the

Make sure that your essay is developed
out of your close
analysis of selected passages found in the readings:

  • Choose one or two short passages
    from the text(s) to help focus your paper;
  • If using a quote, elaborate
    on its meaning using
    words from it. Don’t leave it up to the reader to figure out how
    to interpret the language quoted.

Think about how to organize your paragraphs
to create an
effective argument.

  • Is there a “scheme”
    you can use to organize your
    thoughts to help structure your paper?
  • How will your examples
    “build” upon each other?
    Think of logical possibilities:
    less important to more
    important, or vice versa;
    similar ideas versus contrasting
  • Is there a central concept
    or metaphor you can weave
    throughout your paper to add coherence?

For short papers, start fast.

  • Provide an immediate, specific answer
    to a question posed by the assignment.

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    How (And Why) To Get Into the National Honor Society

    October 22, 2016 |
    Kate Sundquist in Clubs and Organizations , Extracurricular Activities

    Join thousands of students and parents getting exclusive high school & college admissions content!

    The National Honor Society (NHS) is an organization dedicated to recognizing and encouraging outstanding high school students in grades 10-12. Founded in 1921 by the National Association of Secondary School Principals, it was the first nationwide honor society and now has chapters in all 50 states, the District of Columbia, Puerto Rico, and many other US territories. The National Honor Society estimates that today, more than one million students participate in their activities.

    You are probably wondering what qualifies you as an “outstanding high school student” eligible for membership. And beyond that, you may question what sorts of services and activities are required of and provided to members.

    Read on to find out how to get into the National Honor Society, and what you’ll get in return! If you need personalized guidance to strengthen your extracurricular profile, check out CollegeVine’s Mentorship Program for freshmen, sophomores, and juniors. 

    Why should I become a member?

    Being a member of the National Honor Society shows that you are among the best students in your class, not just in terms of academics but also in terms of leadership, service, and character. It shows a commitment to community service projects and provides you the opportunity to network with like-minded peers. College admissions committees like to see anything that sets you apart as a top student, and this is one of them.

    Additionally, NHS provides regular opportunities for you to build your leadership skills. Though not required, multiple conferences and events are available to NHS members throughout the year, including:

    LEAD Conferences: Open to students in NHS, National Junior Honor Society (NJHS), and the National Association of Student Councils, Leadership Experience and Development (LEAD) conferences are held several times a year on weekends in varying cities across the country. They aim to improve leadership skills and provide networking opportunities for peers from around the country.

    National Student Leadership Week: Established in 1972 to promote the value of student leadership, National Student Leadership Week is an open-ended way for schools to celebrate and recognize the importance of student leadership. On their website, NHS provides a list of suggested activities and outreach materials for planning this week.

    State Summits: These local events are available only to students in NHS or NJHS, and they provide the opportunity for students to participate in think-tank style sessions with state leaders. They are designed to spark conversation with the goal being tangible solutions to real problems in schools and communities.

    Finally, NHS also offers college scholarships. Any high school senior who is a member in good standing of a local NHS chapter is eligible to apply for one of the 400 scholarships awarded annually. The 2017 scholarship application will be available online on November 1, 2016 and due on February 1, 2017. More information is available here.

    Who can become a member?

    First of all, it is worth noting that membership in the National Honor Society (NHS) is determined at the local level. Before you find out if you can become a member, you’ll need to locate your local chapter of the NHS. This can be done with a quick search on their Chapter Finder online, or by talking with a teacher or guidance counselor.

    If your school does not currently have a local NHS chapter, you can talk with your principal or an advisor about founding one. Though students are not allowed to found chapters themselves, it is a simple process and one that most administrators can navigate easily. To apply, your school will need to appoint a faculty adviser and a five-member faculty council, fill out an application form, and pay an annual membership fee of $385. If this fee is financially prohibitive for your school, check out our Guide to Fundraising where you’ll find ideas on how to raise the money yourselves.

    All public and accredited private schools are eligible to establish a local NHS chapter, and all students in grades 10-12 who meet the minimum GPA requirements at these schools are welcome to apply. Unfortunately, at this time, homeschooled students are not able to apply, though part-time students may be eligible if permitted by the bylaws of their local chapter.

    Is there any reason that a qualified student should not apply?

    Like any other extracurricular, the National Honor Society requires time and commitment from all of its members. You will be asked to attend regular meetings, and you must participate in chapter and individual service projects. You should check the obligations of your local chapter before making the commitment if you aren’t sure you will have the time or energy to participate.

    How am I evaluated for membership?

    Once you have located your local NHS chapter, you will need to review their membership requirements. Each local chapter sets forth their own unique qualification requirements which must be published and available for review. Although the exact requirements for membership vary by local chapter, all are based on the same four pillars of NHS, detailed below:

    1. Scholarship

    National guidelines require you to be in grades 10-12 and maintain a cumulative GPA of 85 or higher in order to qualify. This is a B average or a 3.0 on a 4.0 scale. Though this is the national minimum, many local chapters establish higher standards, so you will need to check the requirements of your local chapter to see if your GPA qualifies you.

    If your GPA does meet the minimum standard as defined by your local chapter, you will have the opportunity to complete a form detailing your accomplishments in the other three pillars, listed below.   

    2. Service

    Part of your application will ask you to detail your experiences in volunteer work, or other uncompensated, voluntary contributions to your school or community. Some local chapters will require you to have served a specific number of community service hours in order to qualify.  These hours could be spent organizing clothing or food drives, participating in clean up days on campus, or voluntarily tutoring younger students.

    Keep in mind, though, that service hours aren’t something you should be rushing through just to accumulate them as quickly as possible. You should choose service activities with value to you. For more on this, check out the advice in “Do I Need Community Service For My College Application?”

    3. Leadership

    You will also be evaluated for your leadership skills. In this area, you should highlight your experiences taking leadership roles in school and community activities. This could include things like being a team captain, organizing a youth group, or being a part of student government. NHS specifically seeks student leaders who are “ resourceful, good problem solvers, and idea contributors.

    4. Character

    Finally, to gain membership to NHS, you will need to prove that you’re cooperative, responsible, reliable and honest. You should have a clean disciplinary record and show respect and courtesy to those around you.

    Some chapters of NHS might require a written recommendation to vouch for your character. If you need a written recommendation, make sure to choose a teacher who has taught you in a core subject and has known you well for an extended period of time. Meet with the teacher ahead of time to discuss your goals for the application and to talk about why you feel you are qualified to become a member.

    If you meet the minimum GPA requirements for your local chapter, the faculty council will meet to evaluate your candidacy based on your application. They will review each of the characteristics outlined above, and you may be accepted for membership by a majority vote of the five members.

    What happens if I am denied membership?

    If you are denied membership, you may appeal the decision at the local level, but the national NHS organization does not review individual appeals. You may also reapply another year. A rejection of your NHS application does not appear on your transcript or any of your college application materials.

    What happens if I am accepted?

    If you are accepted to the National Honor Society, you will be invited to an induction ceremony with the rest of the newly accepted members of your local NHS chapter. These induction ceremonies are typically public events as the NHS endeavors to inspire others through them. Your parents will be invited, and you can usually invite anyone else who might be interested.

    Though the national office does not dictate a specific format or script for local induction ceremonies, they do dictate that such ceremonies must be “appropriate and impressive”. They also offer a number of ideas and sample programs which can reviewed in their handbook available here .

    In general, the induction ceremony usually includes:

    • A procession or special entrance by inductees
    • Invocation or welcome from the adviser, principal, or chapter president
    • National Anthem or Pledge of Allegiance
    • Guest Speaker
    • Review of criteria for membership
    • Honor Society Pledge
    • Closing remarks

    Many ceremonies also include a candle lighting or other symbolic presentation. Even if you have been accepted in NHS, you are not considered an official member until you have been inducted, signed into your local chapter’s registration, and taken the NHS Pledge.

    Great, I’m in! Now what?

    As a member of the NHS, you’ll need to attend chapter meetings and participate in service projects, both as a group and as an individual. Though it can sometimes be hard initially to come up with new service projects and ideas, the NHS national website maintains a searchable National Student Project Database and a guide to Community Service Idea Starters .

    When you begin a new service project, whether as a group or on your own, you should add your project to the database. You never know when others might want to join you, and your ideas could inspire other people, too!

    Take as much advantage of your membership in the National Honor Society as you can. Attend conferences and events, organize your own events, and apply for the NHS scholarships your senior year! On your college application, being a member of the NHS is a great indicator of your academic successes and generous spirit. But being an active member is even more convincing, as it drives home your leadership skills and dedication.

    For more information about community service, be sure to check out our article, “Community Service, Reimagined: MCC’s Recommendations for High School Service” wherein we summarize some of the main points about service as made by Making Caring Common , a project of Harvard’s Graduate School of Education.

    Or, if you’re curious about how CollegeVine can help you with your college application process, head over to our College Application Guidance Program to see what we’re all about!

    • About
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    Kate Sundquist

    Kate Sundquist

    Senior Blogger at CollegeVine
    Kate Koch-Sundquist is a graduate of Pomona College where she studied sociology, psychology, and writing before going on to receive an M.Ed. from Lesley University. After a few forays into living abroad and afloat (sometimes at the same time), she now makes her home north of Boston where she works as a content writer and, with her husband, raises two young sons who both inspire her and challenge her on a daily basis.
    Kate Sundquist

    Latest posts by Kate Sundquist ( see all )

    • 3 Mistakes to Avoid in the College Planning Process – September 4, 2018
    • 9th Graders: How to Approach High School Successfully – September 3, 2018
    • How to Create a Portfolio for Art School – August 20, 2018

    Related CollegeVine Blog Posts

    • How to Get Into the National Honor Society How to Get Into the National Honor Society
    • Clubs You Can Start in High School Clubs You Can Start in High School
    • National Honor Society Community Service Project Ideas National Honor Society Community Service Project Ideas
    • How Much Do Extracurricular Activities Matter in College Admissions? How Much Do Extracurricular Activities Matter in College Admissions?
    • A Guide to Leadership Roles in Music Groups A Guide to Leadership Roles in Music Groups

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Marketing Manager Cover Letter Sample

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Customize Your Cover Letter to the Ad

Customize Your Cover Letter to the Ad

By Kim Isaacs
Monster resume Expert

Found the perfect job through an ad? Before you whisk off your resume and cover letter, study the ad and determine how your qualifications match the employer’s requirements. Armed with this information, you can craft a cover letter positioning yourself as the ideal candidate.

For example, look at this sample job ad:

Outside Sales Rep

Our client, a fast-growing, Toronto based software company has an opening for an outside sales professional.


  • A minimum of 3 years’ outside business-to-business experience selling enterprise software
  • The ability to develop a list of prospects, build a pipeline of opportunities and close business
  • A proven background working within a quota and exceeding sales targets
  • Ability to demonstrate software and manage a complex sales cycle
  • Strong verbal and written communication skills
  • Availability to travel at least 50%
  • Bachelor’s degree preferred


  • Competitive base salary plus commission and company car.
  • Average first year income $85K+.
  • Full benefits
  • Quarterly sales contests

If you are a true sales hunter and an energetic self-starter with the desire to be part of a fast-growing software firm, submit your resume and cover letter to Brandon Marks at [email protected] Reference #28903888.

A job posting’s Requirements section provides a roadmap you can address point-by-point in your cover letter to build your case to get called for the interview.

Let an expert write you a job-winning resume and cover letter.

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    Marketing Manager
    Cover Letter Sample

    Writing a great Marketing Manager cover letter is an important step in your job search journey. When writing a cover letter, be sure to reference the requirements listed in the job description . In your letter, reference your most relevant or exceptional qualifications to help employers see why you’re a great fit for the role. In the same way that you might reference resume samples , the following Marketing Manager cover letter example will help you to write a cover letter that best highlights your experience and qualifications. If you’re ready to apply for your next role, upload your resume to Indeed Resume to get started.)

    Cody Fredrickson

    (123) 456-7891

    [email protected]

    May 1, 2018

    Dear Hiring Manager,

    I am very excited to apply for the Marketing Manager position at Cloud Clearwater. I find great satisfaction in helping others create and enhance their brands. As a people-pleaser, I will not rest until every client is content with their results. After working in marketing and advertising for over seven years, I’m ready to take my career to the next level at Cloud Clearwater.

    I have spent the last five years as a brand manager at Crane & Jenkins. I oversee the creation and development of logos, digital and print ads and other client-facing marketing materials, all while tending to the needs of the client. I often work with upward of five clients at a time, which gives me valuable experience in prioritization and organization. My responsibilities include coordinating meetings and project deadlines as well as managing a production team.

    The position at Crane & Jenkins allowed me to develop a keen eye for detail when collaborating with graphic designers and copywriters. Earlier in my career, I worked as a graphic designer, so I am also capable of providing assistance and guidance to any creatives I work with when developing a brand. Client satisfaction is always my top priority, and I am willing to put in the time and effort it takes to achieve whatever goals they have set.

    Thank you for taking the time to read this letter and review my resume. I look forward to further discussing this position with you. I am confident that my skills make me a fitting candidate for the Marketing Manager position at Cloud Clearwater, and I am excited to move forward in the hiring process.


    Cody Fredrickson

    Apply for
    Marketing Manager
    Marketing Manager

    Cover Letter Tips

    • In a few sentences, explain why you’re a great fit this specific role. State why you’re excited about the job and the company, and how the job matches your career goals.
    • In one or two paragraphs, connect your past accomplishments with the requirements listed in the job description. Focus on your most relevant experience, qualifications and skills. When possible, quantify your accomplishments with facts and data. Avoid repeating the bullet points from your resume.
    • Close by thanking the employer for their time and consideration. You may also want to sum up your qualifications for the role and express an interest in continuing to the next stage in the hiring process.

    Cover Letters


    Director Marketing
    Insurance Sales
    Sales Director
    Sales Manager
    Sales Support Representative
    Outside Sales Rep
    Regional Sales Manager
    Sales Consultant


    College Resume Tips (with Examples)

    Writing a Resume With No Experience

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    Advertising Sales Agent Cover Letter Sample

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    Vicarious Liability Free Essay


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    The Development Of Vicarious Liability Law Employment Essay

    BLT 2624 Law of Torts II

    Ilya Qistina Binti Abdul Harith 1102701048

    Ervin AK Frankie Jerome 1102700282

    Lim Keelyn

    Nur Fiona Binti Mohd Ali 1102702072

    Regina Saw Lyn Gek 1102702046




    The Tests to Determine Employer-Employee Relationship 8

    The Control Test 8

    Organization Test 9

    Multiple Test 10

    The Case of Imperial Chemical Industries Ltd v Shatwell 11

    Effect of the Case 12


    How Does Vicarious Liability Achieve Social Convenience 15

    How Does It Help To Negate The Liability Of Employee 17


    Cases 21


    Tort law generally concerns matters of private law when a private person has committed a wrong towards another private person such as committing negligence or trespass. Apart from holding the wrong doer or tortfeasor accountable for his or her action, the law on vicarious liability introduces the concept of joint liability whereby an employer or a master will be held jointly liable for the tort committed by their employee. Employee here is given a strict interpretation and is provided with several tests. A person who is of contract for service or a ‘contractor’; where such person’s services are used for its expertise, is not considered as an employee. The law on vicarious liability starts with the tortfeasor being the employee and is followed by tests to determine whether a person is an employee or a contractor. The first test is the control test, the next is the organisation test and the last is the multiple test which will be discussed in detailed further on.

    The tests on determining employer-employee relationship starts through the control test whereby an employee is said to be controlled by an employer. However, today, the job scope of a professional is usually based on their own terms and the job done is not controlled by the employer thus the control test is rendered unsuitable to be used to determine the employer-employee relationship where it involves professionals such as doctors, lawyers or engineers. The next step after determining the employment relationship, the tort done must be ‘in the course of employment’. This means that an employer could only be held jointly liable for the tort committed by an employee if it was done when carrying out work or during working hours. There are several instances where the tort done is considered done in the course of employment. The first is when the act is either expressly or impliedly allowed by the employer. The second is when the employee does something that is authorised in an unauthorised manner or thirdly the employee does something that is closely connected to what he is employed to do in the course of doing the job. [ 1 ] 

    Once employer-employee relationship has been established as well as the tort done is within the course of employment, then only would an employer be held jointly liable for the tort committed by the employee. This has been said to achieve social justice which would be provided for after the evaluation of each part of the test.

    The Development of Vicarious Liability under English Law

    A major portion of primitive law is based on revenge which normally, is arbitrary. The Mosaic Code (Moses Law), however, states expressly that each man should be put to death only for his own sin and not for that of his father or son. The individual defendant in a tort, in a majority of cases are poor and in order to ensure that the plaintiff actually receives the compensation to which he is entitled legal mechanism which enables the plaintiff to fix responsibility upon someone other than the tortfeasor himself was propounded through the principle of vicarious liability.

    The idea of complete liability for the wrongs of servants or slaves during the early Anglo-Norman period slowly changed to the idea of liability only where there has been command or consent on the part of the master of the servant’s wrong. The change continues from 1300 onwards until the early sixteenth century where the command theory has become established. Thereafter, until the seventeenth century, the master’s liability was restricted to cases where he had particularly commanded the very act complained of.

    With rising commercial prosperity and complexities of trade this limited form of liability became inadequate. Sir John Holt (Chief Justice from 1688-1710) established the rule that the master was liable not only for acts done at his express command but also for those done by his implied command. What is to be implied can be inferred from the general authority he had given his servant in his employment (this new rule is stated clearly in the case Tuberville v Stamp [ 2 ] ; the old rule appears as late as in the case of Kingston v Booth [ 3 ] ). This new rule thus, laid down the foundation of the modern law that liability is related to the scope of the employment. The principle of primary liability was still whether the master could be shown to have been a direct participant in the tort as having impliedly commanded it. The master and servant relationship per se was not a legal requirement of liability – it was merely a factual element in the case from which a command could be implied, and other relationships might serve the same purpose equally well. [ 4 ] 

    In 1849 it was finally held that the exercise of master and servant relationship was essential. The master’s liability is derived from the relationship and is truly vicarious. During that time the phrase "implied authority" which had been the primary basis of the master’s liability gives way gradually to the modern "course of employment". [ 5 ] 

    As a matter of law, the defendant (D) will be made vicariously liable for the acts of another person (C) if:-

    C has committed a wrongful act causing damage to the plaintiff;

    Some special relationship exists between D and C, e.g. A contract of employment;

    Some connection exists between the act of C and his special relationship with D, i.e. the act must be in "the course of C’s employment" or in "the scope of C’s authority".

    This principle allows the defendant employer to limit his liability by an express prohibition on certain conduct by his employee such as giving unauthorised lifts in Rose v Plenty [ 6 ] .

    As a general rule, only one special relationship gives rise to vicarious liability, namely, that of employer and employee. A distinction then arose as to whether an employment is a contract of service or a contract for services.

    Historical tests centered around finding control between a supposed employer and an employee, in a form of master and servant relationship. The roots for such a test can be found in Yewens v Noakes [ 7 ] where Bramwell LJ stated that, "…a servant is a person who is subject to the command of his master as to the manner in which he shall do his work."

    The control test effectively imposed liability where an employer dictated both what work was to be done, and how it was to be done. This is aptly suited for situations where precise instructions are given by an employer; it can clearly be seen that the employer is the causal link for any harm which follows. If on the other hand an employer does not determine how an act should be carried out, then the relationship would instead be one of employer and independent contractor. This distinction was explained by Slesser LJ as, liability of the employer arises where he not only determines what is to be done but retains control of the actual performance; but where the employer prescribes the work to be done, leaving the manner of doing it to the control of the doer, then the latter is an independent contractor.

    In Mersey Docks and Harbour Board v Coggins and Griffiths Ltd, [ 8 ] the House of Lords held that the test to be applied should be on "where the authority lies to direct, or to delegate to, the workman, the manner in which the vehicle is driven. It is this authority which determines who is the workman’s superior". In holding as such the House of Lords found the appellant liable vicariously as they still had the power to direct how the driver (whose wages was still paid by the appellant) is to work the crane even though the crane was hired by the respondent from the appellant.

    Liability for independent contractors was found in Honeywill and Stein Ltd v Larkin Brothers Ltd [ 9 ] where photographers hazardously undertook to photograph a theatre interior, and set alight to it.

    The traditional control test to establish liability gives rise to difficulty in recent years, as the duties of employees have grown ever more specialised. Various formulations of the test have been proposed, to rectify these problems. One such formulation focuses on the ability of an employer to specify where and when tasks be carried out, and with whose tools and materials. Other tests focused on different contractual and external factors. Lord Denning, in the case Stevenson, Jordan and Harrison Ltd v Macdonald, [ 10 ]  proposed a test based on the integration of an individual to a business or organisation.

    Tests based on the economic relationship between an employer and employee has found favour in subsequent cases, notably Market Investigations Ltd v Minister of Social Security, [ 11 ]  in the decision of Lord Cooke. It was argued in this case that where a person was in business on their own account (and at their own risk), they would be under a contract for services whilst otherwise they would be under a contract of service. Market Investigations Ltd was cited with approval by the Privy Council, with several relevant factors being considered, such as risk of loss, and chance of profit.

    Liability is thus, generally not extended to the acts of independent contractors. However, there are several circumstances in which an employer may be liable for the acts of contractors such as when the employer directs the contractor to commit a tort or where an employer negligently selected a third party contractor. The broadest exception however is where a non-delegable duty is imposed upon an employer, either by statute or through common law, to prevent the harm of others. Similarly, where a duty is imposed by statute, either to carry out work in a certain way or to take due care in carrying out work, then this is non-delegable. [ 12 ]  Common law duties may arise in several exceptional circumstances, for example, where an activity to be undertaken is especially hazardous, and involves obvious risks of damage. This duty was recognised in Honeywill and Stein Ltd v Larkin Brothers Ltd, [ 13 ]  Finally, where an independent contractor, through negligence, allows fire to spread to neighbouring land the occupier will be held fully liable.

    A new approach in determining vicarious liability was propounded in the Canadian case of Bazley v Curry [ 14 ] whereby the Court laid down the underpinning rationale in finding liability is that of policy and loss adjustment,

    "….the employer puts into the community an enterprise which carries with it certain risks. When those risks materialises and cause injury to a member of the public despite the employer’s effort, it is fair that the person who creates a risk bear the loss when the risk ripens into harm. ….. the second policy concerns, fixing the employer responsible for the employee’s wrongful act may have a deterrent effect."

    Bazley v Curry’s policy approach was adopted by the House of Lord in the case of Lister v Hesley Hall Ltd [ 15 ] and subsequently endorsed by Lord Nicholls in Dubai Aluminium Co Ltd v Salaam. [ 16 ] 

    These decisions have led to a widening of the scope of vicarious liability and a new method of analysis. The class of cases where vicarious liability may be established has greatly increased. The test from Bazley’s case is very valuable in determining borderline cases whether vicarious liability should be imputed onto an employer.

    The Tests to Determine Employer-Employee Relationship

    The nature to determine the differences between employer and employee relationship is important as accepted views is that people who have a contract of service are considered as employees while the worker who have a contract for service is consider as an independent contractor. Over the years, the courts have developed a number of tests in deciding whether a particular person is an employee or not.

    The Control Test

    The control test is also known as the four-fold test. This is because there are four elements that need to be taken into account in using the control test. The first is the right to hire or selection of the employee. The second is the payment of wages and salary. The third is the power of dismissal or the power to impose disciplinary actions and lastly is the power to control the employee with respect to the methods by which work is to be accomplished. [ 17 ] This test was also followed in the Malaysian case of Bata Shoe Company (Malaysia Ltd) v Employee Provident Fund Board [ 18 ] where the elements were applied to the case in determining whether an employee in one of the stores is considered as an employee of Bata Shoe Company or the store itself. It was then held that Bata Shoe Company is the employer thus the worker is an employee because Bata Shoe Company has the right to dismiss the worker.

    Employers or masters will only be liable for the tort of their employees as they are called in law. In the past the usual way of deciding whether a person is an employee is to look at the degree of control exercised over the person’s work by the supposed employer. The control test can be seen in the case of Ready Mixed Concrete(South East) Ltd v Minister of Pensions [ 19 ] , it was stated that a person should be considered an employee if the following criterias are satisfied; First, that the person agrees to provide work and skill for the employer in return of payment. Secondly, that he or she agrees to subject to the employer’s control. Third, that the other terms of the contract are consistent with the existence of a contract of service. Terms which would be inconsistent with such a conclusion might be that the person is required to pay their own materials or is allowed to employ staff to help to do the job. Another factor frequently taken into account is who owns the tools and equipment used to do the job.

    In the past, the control test was the primary indicator used by the courts to determine the relationship between employer-employee. An employer or employee relationship was held to exist when an employer could tell an employee what work to undertake and how it should be done. While this test is still used, the control test, it is clearly outdated in relation to modern work practices. In this modern era of the technological age, the employees are often and frequently expected to be able to exercise discretion and creativity in their performance. Professionals with skills and experience do not expect to be told what to do and how to act during their job

    Organization Test

    This test looks at the integration of the worker into the employer’s business and asks, does the worker economically a dependent to a company or if the worker’s work or activities is an essential component of the business, if the answer is yes, than the worker will be likely to be consider as employee .

    In determining the relationship between the employer and employee, the control test failed to provide for an accurate result therefore the organization test was used in the case of Stevenson Jordan & Harrison Ltd v. MacDonald & Evans [ 20 ] in this case Lord Denning mentioned in his judgement stated that, "it is often quite easy to recognize a contract of service when you see it, but very difficult to say wherein the difference lies. A ship’s master, a chauffeur, and a reporter on the staff of a a newspaper are all employed under a contract of sevice, but a ship’s pilot , a taxi – man, and a newspaper contributor are employed under a contract for sevice. One feature which seems to me to run through the instances is that, under a contract of service, a man is employed as part of the business and his work is done as an integral part of the business, whereas under a contract for services his work, although done for the business, is not integrated into it is only accessory to it." Basically what judge meant was that even though there was a new element in determining the relationship, there is in no way a simple and completely accurate test that is able to determine whether a contract is of service or for service.

    Multiple Test

    From time to time the control test and the organization tests are difficult to apply due to the lack of control of the employers over the method on how the work is to be done. Besides that it also relate to the lack of clarity in the situation. A number of tests were developed by the courts to test the employment status and this includes the economic reality or multiple test.

    The multiple test was put forward by Mackenna. J in the case of Ready Mixed Concrete (South East) Ltd v Minister of Pensions (1968). According to the judge three conditions must be satisfied if the wrongdoer is to be properly considered an employee:

    The employee has agreed to provide skill in return for a wage, a degree of control is exercised by the employer, and any terms found to exist are not inconsistent with employment as such.

    In addition, the courts have found it necessary to take into account numerous factors when considering whether the tortfeasor is an employee, such factors are not conclusive in themselves but help in the process. Factors such as whether the individual owns the tools of his trade, his liability for tax and National Insurance). Also taken into account is the method of payment, does the individual receive a regular payment or wage or does he receive a one off payment once his work is complete?

    The control test is still used, but clearly in the light of these developments, it can no longer be conclusive. The courts now accept that no single test could determine the employer and employee relationship, as well to cover the variety of work situations, and instead they look at all circumstances and facts of the particular case and the level of control. After the earlier test has been criticize for not being able to present a clear relationship, the test based on common sense approach which is the multiple test is use to encounter the problem from earlier test.

    Such can be seen in the case of the Ready Mixed Concrete(South East) Ltd v Minister Of Pensions and National Insurance. There are three elements which the court held that has to be fulfilled to establish contract of service which are the employee or the servant agrees that he will use his own expertise and the employer pays him either in monetary form or in any other form of renumeration. Secondly the employee or servant agrees, whether impliedly or expressly, that he will be bound by the employer’s instructions and thus is reflective of the employer- employee relationship. Thirdly, all other conditions in the agreement are consistent with the nature of the job, which is a contact of service.

    The Case of Imperial Chemical Industries Ltd v Shatwell

    In the case of Imperial Chemical Industries Ltd v Shatwell [ 21 ] , the plaintiff and his brother were were certificated and experienced shotfirers employed by ICI Ltd in a quarry owned by the defendant company. Part of the brothers’ work included wiring up detonators and checking the electrical circuits. There was an old practice where a galvanometer was applied directly to each detonator for testing purposes. They had insufficient wire to test a circuit to allow them to test from a shelter. Another worker had gone to fetch more wire but the brothers decided to go ahead and test with the shorter wire. Each brother claimed against the defendant based on their employer’s vicarious liability for the negligence and breach of statutory duty of the other brother. The defendant raised the defence of volenti non fit injuria in that the brothers the brothers had full knowledge of the risk and were acting against express instructions. [ 22 ] This practice was known to be dangerous and was outlawed by statutory regulation in which the brothers were aware of. The plaintiff claimed his brother was 50 per cent to blame for the explosion and the employer was vicariously liable. The plaintiff was awarded half of the total amount of damages. The defendant appealed.

    In the court’s decision, all 5 judges allowed the appeal and held that the plaintiff and his brother were both experts. They freely and voluntarily assumed the risk involved in using the galvanometer. There was no pressure from any other source. To the contrary, they were specifically warned about complying with the new safety regulations. The defence of volenti non-fit injuria will apply when there is true and free consent to the risk. Thus, the employers were not liable because, firstly the employers not being themselves in breach of duty, any liability of theirs would be vicarious liability for the fault of James, and to such liability (whether for negligence or for breach of statutory duty) the principle volenti non fit injuria afforded a defence, where, as here, the facts showed that George and James knew and accepted the risk (albeit a remote risk) of testing in a way that contravened their employers’ instructions and the statutory regulations. Secondly, each of them, George and James, (the brothers) emerged from their joint enterprise as author of his own injury, and neither should be regarded as having contributed a separate wrongful act injuring the other. The defence of volenti non fit injuria should be available where the employer is not himself in breach of statutory duty and is not vicariously in breach of any statutory duty through neglect of some person of superior rank to the plaintiff and whose commands the plaintiff is bound to obey, or who has some special and different duty of care. [ 23 ] 

    Effect of the Case

    In the context of vicarious liability, this case has considered the topic of volenti non fit injuria [ 24 ] and whether or not an employer could rely on this defence when one of its employees injured themselves while acting in breach of the rules and regulations relating to his job. [ 25 ] In the judgment, [ 26 ] the House of Lords emphasized the distinction between lack of care for one’s own safety and the true acceptance of risk. A plaintiff’s conduct cannot be described as voluntary unless he truly had a free choice. The House considered the origins of the doctrine of vicarious liability and decided that the doctrine of vicarious liability has not grown from any very clear, logical or legal principle but from social convenience and rough justice, and an employer who is himself at fault in persistently refusing to comply with a statutory rule could not possibly be allowed to escape liability because the injured workman had agreed to waive the breach.

    Lord Reid, in his ruling allowing the appeal stated that though "… an employer who is himself at fault in persistently refusing to comply with a statutory rule could not possibly be allowed to escape liability because the injured workman had agreed to waive the breach." and "It was argued that in this case it has not been shown that George [Shatwell] had a full appreciation of the risk. In my view it must be held that he had. He knew that those better qualified than he was took the risk seriously. He knew that his employers had forbidden this practice and that it had then been prohibited by statutory regulation. And he knew that his employers were taking strong measures to see that the order was obeyed. If he did not choose to believe what he was told I do not think that he could for that reason say that he did not fully appreciate the risk. He knew that the risk was that a charge would explode during testing, and no shot firer could be in any doubt about the possible consequences of that. "

    Lord Pearce also is of the same opinion of vicarious liability and added in his decision, "I am not persuaded that there is any reason of principle or policy which can be of substantial guidance in the resolution of the problem of applying the rule in any particular case. Theory may well justify the existence of the concept, but it is hard to find guidance from any underlying principle which will weigh in the decision whether in a particular case a particular wrongful act by the employee should or should not be regarded as falling within the scope of the employment." and "Since contributory negligence has ceased to be a total defence and it has become possible to produce a fair result by apportionment, the reluctance to find the total defence of volenti non fit injuria became more marked …" and "Where Parliament has laid down that certain precautions shall be taken by the master to protect his workman, the master is not and should not be entitled to neglect those precautions and then rely on an expressed or implied agreement between himself and the workman that the latter, if injured as a result of the neglect, will bear the loss alone."

    Viscount Radcliffe stated, "These considerations apart, there are involved in this case questions as to the application of the maxim volenti non fit injuria and as to the principle that in the eyes of the law a man cannot be treated as having disavowed a statutory protection enacted for his benefit in the public interest. On these points, I have had the opportunity of studying in advance the opinions of your Lordships, and I wish to associate myself in particular with the opinion to be delivered by my noble and learned friend, Lord Pearce. I do think it of great importance that the law should not in general allow a person to disqualify himself from the protection of a statutory duty imposed for his benefit, where there is any element of public advantage in upholding the duty. But I do not think that this is a case in which that principle applies."

    Lord Hodson said that a plaintiff’s conduct couldn’t be described as voluntary unless he truly had a free choice. [ 27 ] 

    In the law of tort, there are many other cases which mentions the use of vicarious liability, one such case which deals with principles similar to the case of Imperial Chemical Industries v Shatwell is Stapley v Gypsum Mines Ltd [ 28 ] . The facts of this case was as such; Mr Stapley was killed when a roof of a mine fell on top of him. At the time of his death he was acting against his employers orders. He and another employee Mr Dale had been told to bring the roof down as it was dangerous. The pair knew that this meant that they should not to work in that part of the mine because of the risk. They attempted to bring down the roof but were unsuccessful in their attempts. They then decided to continue with the work they had originally been given. At the time of the collapse, Mr Dale had briefly left that part of the mine and was uninjured. Mrs Stapely brought an action against his employer for breach of statutory duty in relation to the actions of Mr Dale. The trial judge found for the Claimant, but reduced the damages by 50% under the Law Reform (Contributory Negligence) Act 1945. The Court of Appeal allowed an appeal by the Defendant holding that Mr Stapely was solely responsible for his own death. The Claimant appealed to the Lords. The court held at a decision of 3:2 that the appeal was allowed but the damages was reduced by 80%. [ 29 ] 


    How Does Vicarious Liability Achieve Social Convenience

    Vicarious liability is the principle that when an employee committed torts in the course of employment, the employer will be held liable for that tort. Lord Chelmsford once stated that "every act which is done by an employee in the course of his duty is regarded as done by his employer’s orders, and consequently is the same as if it were his employer’s own act." [ 30 ] In order to ensure that the employer will be held liable, several elements need to be established and justified. Those are namely, the act must be a tortuous act, it must be done within the course of employment and

    Vicarious liability is said to help achieve social convenience because it helps to protect the rights of victim so that they are entitled to sufficient amount of compensation which they are entitled to receive. This doctrine is also applicable if the employees had done something that is prohibited by the employer but such act is actually authorised, then the employer would still be held liable. For instance, in the case of Lister v Hesley, the employee was employed as a warden by the employer to take care and supervise a group of boys in a home. The warden then sexually abused the boys that lived in the house. Hence, the court held that the employer is liable because there was a close connection between the employee and the employment. He was in charge of taking care of the child and the abusive act was done in the course of employment [ 31 ] . This case helps to widen the scope of law in such areas so that it is convenient and easier to discover that the employer is responsible for the torts committed by their employees.

    This type of liability helps to achieve and social convenience as well as negate the liability of the employer. This is because an employer is surely in a better financial position if compared to the worker. Hence, they are more capable of paying compensation to the victims. It will help to reduce the number of people being uncompensated in results of the employee can’t afford the amount of compensation being asked by the victims. The employers would be in the best position to mitigate the cost. The employers also earn more salary and most of them are in hold of insurance in order to overcome any unexpected circumstances. For example, in the case of Irving v Post Office [ 32 ] , when an employer knows if there is any terrible situation occurs consequent to his employees act, then he realise that the position he is holding can only be protected by insurance. Hence, that is all they need to do. They will also be able to meet the cost of claims that will be asked by the victims. This is also known as ‘Deep Pocket’s Theory’.

    Not only that, even if the employer have to suffer losses from the liability, they can always recover their earnings by increasing the prices of products or services they provided for the consumers. They have the power to change the nature of level being engaged in regarding the earning or profits. Therefore, such rules will definitely protect the employee from being sued or claimed within the course of employment since they would not be able to pay it.

    This rule also has improved the standards of working environment. When an employer knows that he would be liable for any torts committed by his employee, he will definitely try to control the act of employees and workers. Employers will give more explanations on the manner of how work is supposed to be done. Not to mention, there are also certain employers which provide any courses or talks which will need to be attended by the employees before they can start working in the company. Such imposition of liability also will encourage the employers to be more cautious and alert of what is happening in their company. This type of control will ensure that the business or company is practicing the highest possible standards of safety which will protect the company from being sued. They will provide well-trained workers in the employment. This will assist the country to produce more products of higher quality and consequently, it will help to develop the economic system. Employees also will become more responsible and hardworking.

    Employers will pay more attention towards matters relating to supervising the work done, selection of workers, organisations as well as the discipline and behaviour of the employees. Employers are obviously in the best position to modify the techniques of such production. The similar accidents also can be avoided from happening again in the future. This clearly will enable our morals and healthy workplace culture to get better.

    This rule does not only protect the administrative staff but it also protects those workers who involved in medical department like nurses as well as dispensers. This is because, in appointing the members of staff for medication, the doctor must follow all the rules and regulations provided. They must check the qualifications and which post suits the best with the staff. For example, in Hong Kong, a doctor must, upon making a contract with other healthcare professionals, he must ensure that their qualifications definitely put them in the right position. Few examples of healthcare professionals are the physiotherapist, optometrists, radiographers and others [ 33 ] . With this, such hospitals or clinics would gain more confidence in order to get more patients. In addition, the staff should also undergo an induction for a certain period so that they will get to know and familiar with the environment of the place they are working.

    In the case of Hill v James Crowe, tort is committed by members or workers of a big and successful company, it is very difficult to identify the particular or specific employee that is in fault of causing such damage. This is because, they have too many employees and sometimes the specific person who committed the tort could not be find. Hence, when the employer is automatically liable when such tort was caused within his enterprise, then it will be convenient to identify the target instead of searching one by one.

    How Does It Help To Negate The Liability Of Employee

    This rule helps to negate the employees’ liability in several ways. Once an employee engaged into a contract of service with the employer, they are totally in the control of the employer. Any torts committed by employee in the course of employment will be on the responsibility and liability of the employer. However, it must be based on the justifications of the court.

    When a worker is said to have committed a mistake in the course of employment, while doing something that is authorised by the environment of the employment but he did it in an unauthorised manner, they will also be protected. As what happen in the case of Bayley v Manchester, Sheffield and Lincolnshire Rly [ 34 ] , the porter who works at a train company pulled out one of the passenger from a train as he thought that the person had been mistakenly entered into the wrong train. Hence, the court held that the defendant which is the employer of the porter was held liable even though the act was done by his employee that is the porter.

    Other than that, in the cases of fraud of servant as well, the employer would still be liable just as long as the act was done within the scope of employment and the act is closely connected to the job or task they have been assigned for. In Lloyd v Grace, Smith & Co [ 35 ] , defendant’s clerk persuaded the claimant to transfer her property to him. Therefore, as a clerk, that act was within the scope of apparent authority which he had been given by the defendant (employer). Therefore, the defendant should be held liable.

    This rule also helps to negate the liability of employees in matters where the employees is acting beyond the limits or go against what is prohibited by the employers just as long as it was did in the course of employment. The act also must relate closely to his job then only it will constitute to vicarious liability. In the case of Limpus v General Omnibus Co. [ 36 ] , it involves the employee of a bus company. Generally, every company will strictly prohibited their bus driver from racing with another bus or obstruct other buses. The employee of this company did what is prohibited in which he obstructed the plaintiff’s bus which was from the rival bus companies. Hence, the court held that the driver’s employers will be held liable even though it was the employee‘s fault who did the prohibited act.

    Not to mention, even when an employee committed theft in the course of their employment, the employer could also be liable for that tortuous act. Case in point is Morris v CW Martin & Sons Ltd. [ 37 ] , the employee was told to send the plaintiff’s mink for cleaning purpose. However, the employee then stole it. The court justified that what the employee had done was performing his job but he did it in an unlawful manner. So it was held that employer is liable for the theft committed by the employee because it was done within the course of employment.

    Another way is when an employee breached a statutory duty, employer would still be vicariously liable. For instance, we can look at the decision made by court in the case of Majrowski v Guy’s and St Thomas’s NHS Trust [ 38 ] . In this case, the plaintiff who took an action was the one of the employees of the defendant. He sued the employer for he had suffered sexual harassment at his workplace which means by the employees of the same company. In accordance to the Protection of Harassment Act 1997, any sexual harassment committed within the course of employment is considered to breach this act. Hence, liability is imposed on the employer as his employees had already breach the statutory duty. In order for the employer to escape the liability, it must be proven that such statute or act excludes the vicarious liability whether expressly or impliedly.

    Even when the employee is acting on the ground to benefit for himself, the employer could also be liable. This is the general principle in which decision is depending on the justification of the court. The case of Roshairee Abd Wahab v Mejar Mustafa Omar & Ors [ 39 ] , in an orientation programme, the plaintiff had become deaf after being ragged and assaulted by the defendant’s employees. The government which was the employer nevertheless stated that they had never asked the defendants to do such acts and it is strictly prohibited under the military regulations. The court however held, although they were not trained to do so, they already did it in the performing the duty they have been given. The duty to train in the orientation is an act authorised by the employer but they abused it by carrying out the assault and ragging acts which are improper.

    Hence, from all of the above cases, most important thing that needs to be proven is that the act must be done within the course of employment. Then, it must also be proven that it is closely connected to the job or duty they are performing. From all of the above statement, it was clear that those circumstances help to negate the liability of the employees. It helps to bear the cost burden of employees in the mistakes they have made in doing their job.

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    Vicarious Liability

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    Seminar 7 Vicarious Liability The problem question deals mainly with the issue of Vicarious Liability and Negligence. In order to advise Jerry one would have to explore the rules of vicarious liability, relevant statute law and case law which may apply. Vicarious liability has been defined as the person who commits a wrong must be an employee and not an independent contractor, the employee must have committed a tort and the tort must have been in the course of employment.

    The doctrine of ‘vicarious liability’ is a public policy that holds employers liable when a tort is committed by an employee in the course of their employment. This means that a victim of a tort can claim compensation from the employee’s company if it is proven to have been the employee’s fault that the tort occurred. There are three elements to the doctrine of vicarious liability, where the ‘employee and not an independent contractor’, ‘commits a tort’ and ‘in the course of employment’. There are 3 tests to establish whether an individual is an employee or an independent contractor.

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    These are the control test, integration test and the economic reality test, which is also known as the multiple test. In order to determine who is an employee versus who is an independent contractor, this is illustrated the case of Yewens v. Noakes (1880) 6 QBD, were the respondent was a hop merchant and possessed houses which had internal communication throughout, and were used for the purposes of his trade. K lived in the houses in order to take care of them, and he was a clerk and was paid a salary of ? 150 a year. He resided in the houses together with his wife, children, and servant.

    It was held that K was not ‘a servant or other person’ within Revenue Act 1868 (c 28) s 11 (repealed), and Bramwell LJ stated that “a servant is a person subject to the command of his master as to the manner in which he shall do his work. This case set out what was known as the ‘Control Test’ by way of stating who was an employee and how that employee was controlled by his master. For example, an employee could be controlled in the way he preformed his duties, such as cutting the vegetables this way, holding the knife that way.

    However, this test became one where it could no longer control how employees preformed their duties, given that one can direct an employee to do a task, but could no longer command an employee to do it in a certain way due not having the particular skill needed to carry out the task. For example, an employer could direct a doctor to operate on a patient but not be able to control how that operation is preformed given that the employer may not posses that particular skill.

    The integration test was established in Stevenson v McDonald (1969) and looks at whether the person’s work is an integral part of the business. If they are an integral part of a business, for example a till worker, then they are more likely to be seen as an employee to the courts. If they are not seen as an integral part of the business, for example someone who has come in to fix a till, then they will be seen by the courts as a independent contractor.

    Lord Denning stated that “One feature which seems to run through the instances is that, under a contract of services, a man is employed as part of the business and his work is done as an integral part of the business; whereas, under a contract for services, his work, although done for the business, is not integrated into it but is only accessory to it. ” This refined the control test in order to determine the differences between being an employee and an independent contractor.

    The multiple test was applied in the Ready Mixed Concrete Ltd v Minister of Pensions and National Insurance (1968) where it looked at the contractual relationship between the parties. An individual who has a contract of service is more likely to be seen as an employee by the courts whereas an individual who has a contract for services is more likely to be seen as an independent contractor. The courts may also look at the way an individual is paid. If an individual is paid a salary and they incur for tax reductions, then the individual is ore likely to be seen as an employee. If however, the person is paid a lump sum and has to make their own reduction, they are more likely to be seen as an independent contractor. In this case it was held that the driver was an independent contractor. However in the case of Market Investigations Ltd v Minister of Social Security [1969] 2QB173 Cooke J’s judgment was that “The fundamental test to be applied is this: ”Is the person who has engaged himself to perform these services performing them as a person in business on his own account? This was been determined by using a mix of factors: for example, does the employee provide his own equipment and does he hires his own helpers? It also looks at what degree of financial risk he takes and to what degree of responsibility he has. It also takes into account how the employee is paid and whether the employee can work for another. In this case it was held that Mrs Irving was employed under a series of contracts of service and therefore was an employee of the company.

    Although, Jerry regards Peter as self-employed within his organisation, it would be fair to state that given the control test above, Jerry does have control over Peter by stating that if ever Peter is not available when he wants him he will never employ him again. Peter is free to work for others but does not do so. Therefore the case of Yewens v. Noakes (1880) 6 QBD demonstrates the control that Jerry has over Peter. The Integration Test would also show that Peter could be an integral part of the business given that he does a service rather than offers one.

    This was made clear in the above case of Stevenson v McDonald (1969) where Lord Denning noted the differences between an employee and an independent contractor. Although this new test sets out the real differences, the old test could still hold some merit if the employee is controlled in such a way as to be a servant rather than an accessory to the business. Therefore, if Peter is an employee rather than an accessory to the business this would be examined by the more modern multiple test. This test looks at other factors which don’t arise in the older tests.

    The courts would look as to whether Peter used his own equipment and how he is paid as stated above. Peter does not use his own equipment as he does his deliveries on a motorcycle wearing a uniform provided by Jerry. He is also paid a basic weekly wage, or retainer, plus an hourly rate for every hour actually worked. Based on this and the case of Market Investigations Ltd v Minister of Social Security [1969] 2QB173 it would be clear that Peter is in fact employed by Jerry under contracts of service and therefore is an employee of the company.

    Once it is established that a relationship of employer and employee exists, it is then necessary to establish as to whether a tort has been committed in the course of employment. A test formulated by John William Salmond 100 years ago stated that an employer will be held liable for either a wrongful act they have authorised, or a wrongful and unauthorised mode of an act that was authorised. The courts tend to favor this test as there are no other suitable tests available and the courts usually rely upon precedent, and the facts of each individual case.

    An illustration of the test is provided by two contrasting cases. In the case of Limpus v London General Omnibus Company where a driver pulled out in front of another rival omnibus, in order to obstruct it. Despite having expressed prohibitions, the employer was found liable. This was classified as an unauthorised act of the employee carrying out his duties, which was driving and not an entirely new activity.

    Whereas in the case of Beard v London General Omnibus Company, a conductor was employed to collect fares on board the bus and, thinking he was doing the driver a favor, he negligently chose to drive the bus. This was completely outside of his duties as a conductor. Given the above Peter committed the tort of negligence in the course of employment and although the act was unauthorised it was not outside the course of his duties. Therefore Jerry would be vicariously liable to the claimants.

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      • Compare and Contrast / City Living vs. Country Living

      Compare and Contrast / City Living vs. Country Living Essay

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      Oct 16th, 2010
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      City Living vs. Country Living There are many advantages and disadvantages of choosing to live in the country or to live in the city. But the advantages of living in the country definitely outweigh the advantages of living in the city. In the city, public schools are often packed full of students resulting in larger class sizes and no real teacher student relationship. You would be lucky if your teacher could put a name to your face. Though, bigger schools in the city offer more courses for the student to take and also offer more extracurricular activities. Where in the country, public schools often do not have many students making class sizes significantly smaller resulting in a better teacher student relationship. Your teacher

      …show more content…

      Living in the city, walking down the sidewalks, you do not dare wave to the people as you pass, let alone stop to talk with them. If you are going to be away from home for any length of time, chances are you do not even want your neighbors to know this. They may be the people you need to be leery of. If you are stuck in a situation at work that you cannot make it home before your kids, you will either have to make arrangements with your spouse, or maybe you have a daycare you are familiar with and trust that they could go to, because the neighbors house is the last place you would want to send them, after all, living next to them, you see what kind of activities go on in their household. Living in the country, you know your neighbors personally. When out for a walk, they wave to you as you pass by. They may even stop to chit chat, to see how things are going, to catch up on the latest news in the neighborhood. If you are out of town, you do not have to worry about something happening to you house while you are away. Your neighbors keep a good watch over it. Or, if something comes up at work and you cannot make it home before your kids get off the school bus, your neighbors are just a phone call away and you can be sure they would be happy to do a favor for you by letting the kids get off the bus at their house. You know your kids will be safe with them, and they will probably even be fed by the

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      • Compare and Contrast / City Living vs. Country Living

      Compare and Contrast / City Living vs. Country Living Essay

      971 Words
      Oct 16th, 2010
      4 Pages

      Show More

      City Living vs. Country Living There are many advantages and disadvantages of choosing to live in the country or to live in the city. But the advantages of living in the country definitely outweigh the advantages of living in the city. In the city, public schools are often packed full of students resulting in larger class sizes and no real teacher student relationship. You would be lucky if your teacher could put a name to your face. Though, bigger schools in the city offer more courses for the student to take and also offer more extracurricular activities. Where in the country, public schools often do not have many students making class sizes significantly smaller resulting in a better teacher student relationship. Your teacher

      …show more content…

      Living in the city, walking down the sidewalks, you do not dare wave to the people as you pass, let alone stop to talk with them. If you are going to be away from home for any length of time, chances are you do not even want your neighbors to know this. They may be the people you need to be leery of. If you are stuck in a situation at work that you cannot make it home before your kids, you will either have to make arrangements with your spouse, or maybe you have a daycare you are familiar with and trust that they could go to, because the neighbors house is the last place you would want to send them, after all, living next to them, you see what kind of activities go on in their household. Living in the country, you know your neighbors personally. When out for a walk, they wave to you as you pass by. They may even stop to chit chat, to see how things are going, to catch up on the latest news in the neighborhood. If you are out of town, you do not have to worry about something happening to you house while you are away. Your neighbors keep a good watch over it. Or, if something comes up at work and you cannot make it home before your kids get off the school bus, your neighbors are just a phone call away and you can be sure they would be happy to do a favor for you by letting the kids get off the bus at their house. You know your kids will be safe with them, and they will probably even be fed by the

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      Life and style

      City v country: where’s the better place to live?

      Big metropolis or big yard? Culture or nature? Heather Long and Jessica Reed debate the merits of urban lifestyle and rural retreat


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      The case for living in the country

      Heather Long_140x140

      Big city glamor? Balderdash. Try big city cost. If you want to live like a king (or at least be your own landlord), move to the country.

      1. It’s cheap. You have to actively try to spend more than $20 on a meal, even a good one. A movie still costs single digits. No one has a clue or cares what brand of clothing you’re wearing, let alone whether your shoes, purse or belt are this year’s season or last. And did I mention housing? You can live in a real house with multiple bedrooms, multiple bathrooms and a garage. Maybe even a pool. And you can own it for under $200,000 . Yup, you read that right. I didn’t leave off any zeros.

      NYC subway ad

      2. There’s space – for you, for your dog, for your kids, between you and your annoying neighbors. An ad on the NY subway sums up: “Raising a baby in an NYC apartment is like growing an oak tree in a thimble.” In the city, you live on top of each other. Your kids and your dog barely know what grass is. In the country, you have something called a yard. You run around, kick a football and chase fireflies. You go sledding and build snowmen on fresh snow that hasn’t been trodden by hundreds of others. You can actually identify constellations because you see lots of them each night. You are fascinated by a lot more interesting animals than squirrels , and your dog acts like a dog, you don’t have to carry around bags for its poop.

      3. There are no billionaires. And frankly, few millionaires. To put it another way, there’s a lot less income inequality. Since the cost of living is much lower, even those on the median family income ( about $50,000 in the US ) can have a decent life. You don’t feel poor as you do in big cities where even those earning six-figures still believe they’re ” just getting by “. In the country, you aren’t constantly aware of your socioeconomic status. You worry a lot more about the weather.

      4. You aren’t reliant on public transit. You don’t have to push your way onto an overcrowded subway car only to find yourself squashed next to someone who smells or elbows you. You aren’t late because there’s been a delay and some robot-like voice has to tell you about it over and over on the speaker. You can drive yourself where you want, when you want. Even if there’s traffic (and there isn’t much outside of cities), you can usually find another way to go. You are in control, and there’s plenty of (free) parking.

      5. You don’t get suspicious when people are nice to you. People say hello and “how are you” and generally mean it. You go to the grocery store and have a decent chance of seeing at least someone you know. Your doctor actually calls you back the same day you call with a concern. People don’t size you up constantly based upon your job, social status or income. Volunteer work isn’t something you do for your resume. You feel a part of a genuine community, not just one peon out of millions.

      The case for living in the city

      Jessica Reed

      The countryside? It must be nice if you’re retired … or dead. If you want to have a semblance of a social life and like to do wild things like, oh, going to the cinema on a Monday night, the city is for you.

      1. Walking. It’s a thing. Forget about having to spend a quarter of your paycheck on a car. Forget about feeding your second-hand beater gallons of earth-destroying gas on a weekly basis. And (unless you live in LA) forget about spending two hours a day stuck in traffic. Living in the city means that walking is often an option. And if it’s not, commuting by public transport makes you feel like you’re part of the world: you and others are on the same boat, so to speak, taking time to pause and read, or listen to music, before reaching work or going home. And, from London to Paris, Amsterdam to Vancouver, chances are you will be also be lucky enough to be able to bike everywhere – making you both fitter and happier.

      2. You will never be the underdog. As Daria would tell you, it sucks to be the odd one out. If you’re a goth, head to London’s Camden Town, which will love to have you. You like playing in all-female netball teams? You’ll find a club. Love mushroom-hunting? Start your own group. In Sydney, where I live, my local park alone is the home to joggers, skateboarders, tai chi lovers and tight-rope walkers. There’s something for everyone. And kiss bigotry goodbye, too: if you’re gay, you will easily find both a welcoming environment. And better dating prospects.

      gilmore girls

      The countryside: not like Gilmore Girls

      3. The entire world is (almost) on your doorstep. I don’t know about you, but it would be a shame to die on the way to the hospital – or give birth on the side of a road. Which probably won’t happen in the city. You can order anything from online stores and – miracle! – receive it the next day. Museums, galleries, libraries are easily accessible, a lot of them free. And food: enough said. Who likes to have the choice only between a grim pub serving dismal burgers or fish-and-chips and the local Subway branch at the back of a derelict mall? Not me.

      4. It teaches you tolerance. The world is a diverse place – and in the city, you learn that fast. There’s a reason New Yorkers are considered to be the most thick-skinned people on earth: nothing fazes them, because no one has time to be fazed and they’ve seen it all anyway. Someone is rude to on the subway? Move along. Someone cuts you while queuing in the supermarket? Get ahead and get even. But cities also teach patience and empathy because, after all, you’re all in this together. Compromise is in the very fabric of city living. Neighbours complaining about your Saturday party? You have to reach an agreement. People who don’t act, think, or speak like you do? Kids who annoy you by listening to rap music in the bus? They share your space, too. And you, theirs. It’s an imperfect and fragile microcosm, which, no matter its many drawbacks, seems to work. Almost like magic.

      5. The countryside is not like living in Gilmore Girls . If you think the countryside is like living on the idyllic Gilmore Girls’ set , you’re mistaken. Nor are you likely to live the Good Life, a la Helen and Scott Nearing , who fed themselves thanks to their homestead until they both died. True country-living means backbreaking work, including thankless chores performed before dawn. Here in Sydney, I pop to the corner shop to get eggs at midnight if I want. And if you’re not a true back-to-the-lander living on a 120-acre farm in the middle of nowhere, you then have to live in a community where everything you do will be scrutinised. Privacy will be hard to maintain. No such thing will happen in the city, where people couldn’t care less whether you like to walk around with your pet snake, like to wear mini-skirts in sub-freezing weather, or sing Bryan Adams’ Everything I Do I Do It For You out loud while on your way to buy a baguette. Short of becoming a hermit , if you’re a private individual or an introvert, city life is for you.


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      UTS Unreserved Ticketing System


      UTS on mobile app is an Indian Railways official android mobile ticketing app to book unreserved train tickets.

      Paperless ticket has been enabled in entire Chennai suburban section, entire Mumbai suburban section and New Delhi – Palwal section, in continuation of Paperless ticket now Season and Platform Tickets are introduced. In addition to that, now ‘Change Handset’ feature is introduced which is used to Change passenger old handset to new one, and active Season Ticket will transferred from old handset to new one.

      Using ‘show ticket’ feature the ticket can be showed to the TTE(Travelling Ticket Examiner) or TC. Off-line mode is available to show the paperless ticket if Internet connection not available in the mobile.

      Types of Essay



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      Word Counter Blog

      The Different Types of Essays

      different types of essays

      To succeed at school, you need to be able to write different types of essays . Your teachers will seldom tell you exactly which type of essay you should be writing , so you need to be able to figure it out from the question you have been asked. Once you’ve identified the right type of essay to answer the question, you’re not home free yet, but at least you’ll know how to structure it and what type of content to include.

      There are various opinions on how to categorize essays and how many types of essay there are. The simplest interpretation says that there are only four types of essays:

      1. Narrative essays
      2. Descriptive essays
      3. Expository essays
      4. Persuasive essays

      I personally think this is a bit of an oversimplification. I also think there are overly complicated classifications of essays, so to keep things relatively simple, we’ll stick to 10 types. Feel free to disagree with me if you like!

      Descriptive Essays

      In this type of essay, you’re painting a word picture. You can certainly include some facts, but you’ll focus on the experience, what it feels like, looks like, smells or sounds like. Your aim is to draw the reader in so he or she can experience what you are writing about in the same way you experienced it.

      Definition Essays

      A definition tells you what something is. Although a definition is short, a definition essay discusses a complex concept in much greater depth than you would get from a few lines. They’re most often used to discuss philosophical or abstract topics.

      Compare and Contrast Essays

      You’ll be given two similar-seeming yet different things to compare. To write this essay, I suggest that you prepare carefully. Which elements are the same? Which ones are different? Once you are sure you know what information you want to include, you’re ready to go.

      Cause and Effect Essays

      Although the name seems self-explanatory, we need to remember several causes can contribute to a single effect, and conversely, one cause could result in several effects. For example, several factors contributed to the US involvement in the First World War (multiple causes, single effect). However, being in the war had several effects on the US (single cause multiple effects).

      Narrative Essays

      If you like creative writing, these will be among your favorite essays. In a narrative essay, you tell a story. Remember, it has a beginning followed by a number of events that lead up to an ending. Plan carefully!

      Process Essays

      This type of essay involves a step by step explanation of how something happens or is done. Getting your steps in the correct order is important if you don’t want to turn your process into a muddle. Write your process essay in chronological order.

      Argumentative Essays

      Are you opinionated? Good! The argumentative essay explains your opinions and the reasons why you believe they’re right. You can even look at some possible counter-arguments and why you believe they’re wrong. Ultimately, you’re trying to get your reader to agree with you, so the more facts you can present to support your points, the better.

      Critical Essays

      You don’t have to criticize the thing you’re writing about unless you think there is reason for it, but you’ll be evaluating it critically. You’ll provide reasons why you think something was well done or badly done. If you think it was great, why did you think so? Are there any faults that bothered you? Why did they bother you? What evidence can you present to support your opinion?

      Expository Essay

      You could sum this type of essay up as follows, “Get all the facts, and then interpret them!” You must reach a conclusion , and this has to be supported by your research or personal experience. In higher education, you have to show your ability to research your topic, and you’ll probably be citing experts along the way. In the end, you give your own opinion, but you’ll point out how several sources contribute to it. As long as there is logic in that, your answer can’t be wrong. These essays are exciting because even when you use existing knowledge, you may find yourself obtaining a new perspective or reaching a novel conclusion.

      Persuasive Essays

      In a way, these are similar to argumentative essays, but they’re not quite the same. An argumentative essay will hit people with the facts, while a persuasive essay has a softer touch and may appeal to moral values or emotions. See it as the difference between winning a debate and winning someone over to support a cause. There are differences, but also similarities.

      What Type of Essay to Write?

      When looking at an instruction or exam question, study the VERBS your teacher has used. Circle them and think about what they imply. If you’ve just been told to name or list things, give nothing but the facts.

      Other words indicating that you should usually give nothing but the facts:

      • Analyze
      • Explain
      • Illustrate
      • Prove
      • Show
      • Compare
      • Contrast
      • Discuss

      In addition, you want to look for words indicating that you should give your opinion:

      • In your opinion…
      • What do you think about…
      • How do you feel…

      If you have any doubt about the type of essay you should be writing, ask. While your teacher likely won’t tell you when assigning, she will explain the correct type of essay to write for the particular situation and how you can figure that out. This should prove beneficial so you can deduct the correct type to write in future situations.

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    • I don’t understand why we even have to write essays. I think it’s just a device teachers have come up with to torture us. Nobody would ever voluntarily write an essay!

      • So, what would you write? What would improve your writing skills? And why do you see writing as torture?

    • Very good blog post. As a student teacher, it’s important for students to understand the wide variety of essays and the appropriate one to use with each assignment. I absolutely love this site. Keep it up!

    • what about the reflective essay?

      • Reflective! Excellent point. I have a much longer list than this (I am an English teacher), but reflective is not on it — well, it wasn’t until now!

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      Ready to
      make a difference in the marketplace? The Master of Business Administration
      (MBA) degree at North Greenville University was designed to provide students
      with a comprehensive education in each of the major business disciplines as
      well as insights into the biblical principles that guide Christian leaders.
      Faculty in the MBA program provide both subject expertise and practice
      experience with a focus on strategy, analysis, operations, and leadership. Our MBA program was ranked 20th in the top 50 most affordable MBA degrees in 2016. We strive to have one of the best MBA degrees in South Carolina and the Southeast.


      Quick Facts


      • 36 �
        Credit hours in the MBA degree at NGU

      • 18 �
        Months to complete your degree
      • 8 �
        Weeks per term
      • 5 �
        Start dates throughout the year
      • 3 �
        Formats for your study: On-Campus, Online, or Hybrid
      • 0 �
        Years of business experience required




      The 36-hour MBA program at NGU is designed to develop
      trained and skilled business leaders who make a difference. The degree sets
      students apart by providing training in all areas of business necessary for
      executives � such as organizational dynamics and customer demand, personnel management,
      and entrepreneurship � to teach students business, analytical, and
      critical-thinking skills with a Christ-centered focus. At NGU, our world-class
      faculty members enable students to challenge the status quo, discover their own
      paths, and develop into more effective and impactful professionals.

      With one of the top MBAs South Carolina has to offer, you�ll become prepared for various business executive positions you may want to pursue by gaining the necessary knowledge and skills required, including the following:

      • Business
      • Decision-making
      • Economics
      • Entrepreneurship
      • Financing
      • Human
      • Leadership
      • Managerial
      • Marketing
      • Organizational




      • Understand the objectives and basic elements
        of strategic management.
      • Understand and be able to analyze and
        evaluate the external environment, specifically the context in which an
        organization must operate.
      • Understand and be able to analyze and
        evaluate the internal environment of an organization.
      • Identify and use a range of analytic tools
        appropriate for strategic planning.
      • Apply the analytic techniques in various
        situations to arrive at appropriate decisions upon which a strategy can be
      • Gain hands-on experience working in a group
        to develop a strategic plan for a privately-held corporation.
      • Integrate Christian principles with strategic
        decisions, including, but not limited to, ethical principles, competitive
        intelligence, the exercise of strategic leadership, etc.
      • Develop an appropriate concept of the
        professional�s moral and ethical responsibilities.
      • Develop team building, collaboration, and
        respect for differing opinions through thoughtful discussion of hot topics, as
        well as improved oral communication and presentation skills.





        For business leaders with a focus on the impact of human capital, NGU offers a Human Resources MBA track focused on the trends, laws and changes in human resource practices.  The program also leads to the highly-recognized SHRM-CP or SHRM-SCP credentials which are the primary professional certifications within the field of HR.  Another unique advantage of the HR MBA from North Greenville University is the broader business curriculum it includes, designed to equip graduates for a wide number of opportunities in for-profit and nonprofit organizations.

        To earn the human resources concentration, complete the following courses:

        BUSN 5341 Human Resources Selection and Placement (3 credit hours)
        BUSN 5342 Human Resources Compensation and Development (3 credit hours)
        BUSN 5343 International Human Resources (3 credit hours)
        BUSN 5344 Strategic Issues in Human Resources (3 credit hours)

        Typical career tracks for graduates of the MBA Human Resources degree include:
        Human Resources Manager, HR Specialist, HR Recruiter, Chief Learning Officer, Compensation & Benefits Manager, Industrial Relations Director, HR Consultant



      Career Opportunities


      • Budget
      • Business
        Operations Manager
      • Compliance
      • Financial
      • Financial
      • Hospital
      • Human
        Resources Manage
      • Medical
        and Health Services Manage
      • Nonprofit
      • Public
        Relations Manager 




      • Boy
        Scouts of America
      • Chick-fil-A
      • Esurance
      • Fluor
      • Greenville
        County School District
      • Greenville
        Health System
      • Hammett
      • Marriott
      • Michelin
        North America
      • Robert
        Half International
      • United
        Parcel Services
      • United
        States Army
      • Verizon
      • Wells



      To apply to NGU�s MBA program, complete the following

      1. Fill in
        the online graduate school application .
      2. Send the
        following documents to NGU�s Office of Adult and Graduate Admissions at 405
        Lancaster Ave., Greer, SC 29650:
        1. A self-reflective
          essay of 500 words, explaining why you want to pursue a degree at NGU�s
          graduate school
        2. A check
          for the $30 application fee
      3. Download, print, fill in, and share the
        required reference forms:
        1. Two Employer / Professional Reference Form
        2. One Personal Reference Form
      4. Contact the registrar for all previous colleges or universities you’ve
        attended and have them send your official transcripts directly to
        the Tim Brashier Campus at 405 Lancaster Ave. Greer, SC 29650.


      Curriculum Structure


      The curriculum for NGU�s MBA degree consists of 12 prescribed
      courses to be completed in consecutive eight-week terms. Full-time students
      take two courses per term for a total of six terms. Those who have not
      completed the undergraduate prerequisites in statistics and accounting will be
      required to take them prior to admission into the program.

      Students have the option of adding a human resources
      concentration by completing four additional courses that focus on different
      aspects of human resources.

      This 36-hour degree is comprised of study areas necessary
      for effective business leadership. The program offers rolling enrollment, with
      five 8-week terms per year. Students may choose to enroll fully online or fully
      onsite, or they can select a hybrid combination of the two formats.




      If you would like to complete your MBA degree in the
      suggested time frame of 18 months, then we recommend taking a full-time load of courses
      each term in the following order:




      Students must have already completed a statistics and
      accounting course during their undergraduate work and earned a letter grade of
      B or higher in order to continue through the MBA program at NGU.


      Core Courses 


      These courses are all required by every student:


      Term 1

      BUSN 5000 Organizational Behavior (3 credit hours)

      ACCT 5310 Managerial Accounting (3 credit hours)


      Term 2

      BUSN 5325 – Business Analytics (3 credit hours)

      MRKT 5310 The Marketing Process (3 credit hours)


      Term 3

      BUSN 5350 Research Methods in Business (3 credit hours)

      ECON 5310 Managerial Economics (3 credit hours)


      Term 4

      BUSN 5340 Human Resources Management (3 credit hours)

      BUSN 5380 Financial Management (3 credit hours)


      Term 5

      BUSN 5360 Operations Management (3 credit hours)

      BUSN 6300 Business Strategy (3 credit hours)


      Term 6

      BUSN 5315 Small Business and Entrepreneurship (3 credit

      BUSN 5100 Issues in Professional Ethics (3 credit hours)


      Human Resources Concentration Courses (optional)


      To earn the human resources concentration, complete the
      following courses:

      BUSN 5341 Human Resources Selection and Placement (3
      credit hours)

      BUSN 5342 Human Resources Compensation and Development (3
      credit hours)

      BUSN 5343 International Human Resources (3 credit hours)

      BUSN 5344 Strategic Issues in Human Resources (3 credit


      Course Descriptions


      These are the MBA program courses offered at NGU and their
      respective course descriptions, listed alphabetically:

      5310 Managerial Accounting
      (3 credit hours) � A study that includes the
      creation, use, and interpretation of internal accounting data and information. Emphasizes
      the managerial functions of cost control and reporting, budgeting, profit
      planning, and projections. (Prerequisite: BUSN 5220)


      5000 Organizational Behavior
      (3 credit hours) � An in-depth study of
      management and organizational behavior theories, basic principles and processes
      from their historical foundations to today’s best practices. Focuses on how
      managers influence their employees to accomplish organizational objectives.
      Also includes an emphasis on management and organizational behavior issues
      involving organizational culture, structures and systems (e.g., bureaucracy),
      authority, communication, structure, ethics and social responsibility,
      motivation, leadership, decision-making, group dynamics, conflict resolution,
      stress, change, and problem-solving.


      5100 Issues In Professional Ethics
      (3 credit hours) � A detailed study of
      ethical issues encountered by professionals in the contemporary cultural
      setting. Traditional Judeo-Christian values and teachings will be explored as
      they relate to practical applications in business and the professions. Questions
      related to human experiences with areas such as truth telling, conflict
      resolution, relation to government, poverty, and ethnic, cultural, and racial
      differences are addressed in the context of Christian leadership and


      5220 Introduction to Accounting and Finance
      (3 credit hours) � A study
      of accounting and finance with emphasis on using financial data for decision
      making; measuring, reporting and analysis of financial information; discounted
      cash flow analysis, project analysis and introduction to the measurement of
      risk and return. Students may exempt this course by submitting evidence (to the
      Graduate Registrar) of satisfactorily completing prior coursework or requesting
      approval by the Dean of the Graduate School of Business of relevant work
      experience in accounting or finance.


      5315 Entrepreneurship and Small Business
      (3 credit hours) � A study
      that explores the concepts and applications of sustainable business including
      creating, leading, and managing business enterprises. Examines approaches for
      leading entrepreneurial individuals and companies. Analyzes innovation issues
      including creating and realizing value, prioritizing opportunities, and
      managing the innovation process.


      5340 Human Resource Management
      (3 credit hours) � A study of the concepts
      and techniques of manpower planning, job evaluation, incentive and performance
      standards, and the impact of labor organizations benefits. Creates a
      problem-solving environment designed to integrate knowledge in various
      functional areas of business.


      5341 Human Resources Selection and Placement
      (3 credit hours) � A study
      of the processes by which the workforce is built that will enhance productivity
      and effectively implement business strategy. Examines the activities of
      identifying, attracting, and acquiring the optimum human assets who best fit
      the work needs and the organizational culture and who will enhance innovation
      and decision-making. Also analyzes the processes by which human assets are
      retained and integrated into a firm’s operations so that cooperation and
      collaboration are maximized. (Prerequisite: BUSN 5340)


      5342 Human Resources Compensation and Development
      credit hours) � A study of the the overall understanding of compensation and
      benefits and the related environments in which they are practiced. Highlights compensation
      system design, related criteria, and the selection and effective administration
      of employee benefits. Addresses the ways tangible and intangible forms of
      compensation may be used to motivate and reward employee performance, and future
      challenges that businesses will face in the arena of employee compensation and
      benefits. (Prerequisite: BUSN 5340)


      5343 International Human Resources
      (3 credit hours) � A study of human
      resources from an international perspective. Compares industrial relations and
      HRM literature and focuses on aspects of HRM in multinational firms.
      (Prerequisite: BUSN 5340)


      5344 Strategic Issues in Human Resources
      (3 credit hours) � A study
      in building measurement strategies for all HR activity so that the impact can
      be determined. A value-adding approach will be taken so that HR practitioners
      will be able to exhibit an understanding of the business. Includes aspects that
      influence organizational quality, productivity, services, and profitability. (Prerequisite:
      BUSN 5340)


      5350 Research Methods in Business
      (3 credit hours) � A study that emphasizes
      the processes of determining, acquiring, analyzing, synthesizing, and
      disseminating relevant data, information, and insights. This course, in
      conjunction with the capstone course, serves in lieu of a senior thesis.
      (Prerequisite: BUSN 5320)


      5360 Operations Management
      (3 credit hours) � A study providing a basis
      for understanding the importance of managing and coordinating production
      decisions, how those decisions affect the supply chain of a firm, and the
      interrelations between operations and other functional areas within a firm. (Prerequisite:
      BUSN 5320 recommended, but not required)


      5380 Financial Management
      (3 credit hours) � A study that involves in-depth
      discussions of working capital management, capital budgeting, the cost of
      capital, debt, and equity financing; and financial statements. Analyzes the
      effects of multinational operations, multiple currencies, international tax
      laws, money and capital markets, and political risk environments.
      (Prerequisite: BUSN 5220)


      6300 Business Strategy
      (3 credit hours) �The capstone course in the
      MBA curriculum.  Students will learn to
      understand, analyze, and evaluate the competitive climate in which a firm
      operates, its internal capabilities and intents, and to apply analytic
      techniques to arrive appropriate decisions upon which a strategy can be
      crafted. Students will work with a real company for their capstone project.
      (Prerequisite: 30 credit hours in the MBA program, which should include BUSN
      5380, MRKT 5310, and BUSN 5350)


      5310 Economics for Managers
      (3 credit hours) � A study that provides a
      consistent framework of economic analysis to help decision makers adapt to
      government regulations and other external factors. Students apply relevant
      economic theory to business problems and develop general principles that can be
      applied to the business decision-making process.


      5310 The Marketing Process
      (3 credit hours) � A study that focuses on
      the major controllable marketing variables of product, price, promotion, and
      distribution. Explains key marketing concepts, such as consumer decision-making
      processes, market segmentation, and development strategies and their
      significance in domestic and international activities.


      For more
      information on our upcoming terms, course offerings, and the textbooks you�ll
      need, follow the links below:

      • Academic Terms
      • Required Textbooks


      All Graduate School of Business faculty members at NGU hold relevant degrees in various business-related areas. Additionally, faculty members are experienced business people who are seasoned leaders in many areas of business. 

      Students in NGU�s MBA program are taught and mentored by these highly credentialed faculty, who not only possess years of experience in their respective fields of study, but also enable students to think critically and develop into more effective and impactful business leaders. The faculty’s combination of industry experience and strong education backgrounds make NGU one of the top MBA programs in the region.


      Tracy Kramer, Ph.D.

      Dean of the Graduate School of Business

      Dr. Tracy Kramer has been at North Greenville University
      since 2006. She received her doctorate from the University of Alabama and taught at
      George Mason University and Erskine College before joining the faculty at NGU. While
      her primary area of study is strategic management, specifically small business
      and non-profit growth, she is also a certified etiquette and protocol
      professional. She delivers speeches and writes on the topic of professionalism
      and serves as a consultant to companies. Kramer�s husband, David, is an
      entrepreneurial engineer with a private business in automation and control.
      They have two children, Brad and Natalie, and two dogs. Kramer serves on the
      Board of Directors for Junior Achievement, the Leadership Development Committee
      for the Greer Chamber of Commerce, and the Moonlight and Magnolias Committee

      for the American Cancer Society.

      Ronald E. Gregory, Ph.D.


      Dr. Ron E. Gregory, a
      native of Greenville, graduated from Furman with his
      bachelor�s, earned a doctorate and MBA degree from Clemson, and joined
      the NGU Graduate School faculty in 2011, where he now serves as the dean
      of the MBA program. His business background is in finance and real
      estate, and his academic concentrations are economics, finance and
      related fields, and entrepreneurship. He has one son and one
      granddaughter who live nearby. He is an active student of local history,
      especially the early settlement of Greenville and business leaders
      prior to the 20th century.


      If you�re a prospective student who�s interested in this
      degree at NGU, then you can contact our Office of Adult and Graduate Admissions
      directly to learn more:

      Maria A. Kithcart, ABD
      Associate Director of Adult and Graduate Admissions Counselor
      Local: 864-663-7522
      Toll Free: 1-844-333-4566
      [email protected]

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      Master in Health Administration

      College of Health Professions

      College of Health Professions  :  Master in Health Administration

      Master in Health Administration

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      Human Anatomy and Physiology

      Course Code:
      Credits: 4

      Diploma level anatomy and physiology course designed for students in Health Sciences or Health Care programs. Students will have the opportunity to study the human body and apply the knowledge during on-line chat sessions. This course is suitable for admission to Health Care programs and may be considered for advanced standing.

      Learn more about this course:

      On-Line Classes

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      Term: 2018 Fall (1184)Classes End: December 18, 2018

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        Part-Time Studies

        Human Anatomy MOOCs and Free Online Courses




        Statistical Shape Modelling: Computing the Human Anatomy (FutureLearn)
        Feb 26th 2018
        University of Basel

        Learn the technology of modelling, as used in computational face recognition or in surgeries, with this free online course. Statistical shape models are one of the most important technologies in computer vision and medical image analysis. With this technology, the computer learns the characteristic shape variations of an object or organ. The model resulting from this analysis may then be used in implant design, image analysis, surgery planning and many other fields.

        CS: Artificial Intelligence, Robotics & Computer Vision , CS: Information & Technology , Sci: Mathematics
        Computing , Human Anatomy , Shape Modelling , Modeling , Statistical Modeling , Computer Vision , Medical Image Analysis
        More Info
        Human Anatomy (edX)
        Self Paced
        The Hong Kong Polytechnic University

        Explore the structure of the human body through a real life case scenario of stroke from six healthcare professional perspectives. Human Anatomy is fundamental to every medical and healthcare professional. However, the science of anatomy and effects of stroke are also extremely useful to anyone interested in understanding more about the human body.

        Sci: Biology & Life Sciences , Medicine & Pharmacology
        Human Anatomy , Biology , Human Body , Health
        More Info
        Human Anatomy Lab (
        Not Available
        Saylor Academy

        Although we cannot virtually replicate the lab experience, this “lab” will familiarize you with scientific thinking and techniques and will enable you to explore of some key principles of human anatomy.

        Sci: Biology & Life Sciences
        Anatomy , Human Anatomy , Human Body , Biology
        More Info


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