Does the law in ADAMS v CAPE PLC still good law or should further reform prevail - Free Essay Example

Does the law in ADAMS v CAPE PLC still good law or should further reform prevail? The approach in Adams v Cape plc in lifting the veil of incorporation has always been a debatable issue. Despite the obvious economic connection between companies within the same group, English company law has steadfastly maintained its policy of treating such companies as distinct legal entities. . To lift or not to lift the veil of incorporation is a matter for the court to decide in each and every case. Should the approach in Adams v Cape plc ltd (1990) continue to be used or statutory provisions should come into play? Years ago the English Courts had established the basic principle of separate corporate personality: à ¢Ã¢â€š ¬Ã…“the corporation has a separate existence from the shareholderà ¢Ã¢â€š ¬Ã‚  per Vaughan Williams J in Salomon v Salomon. It is the leading case on the fundamental importance of the separate personality of a company. A distinct legal personality can own and deal with property, sue and be sued in its own name and contract on its own behalf. The emergence of group structures in UK was to curtail tax as the Corporate Structures became more prominent. When we speak of lifting the veil of incorporation it equals to a veil which stands in between the company and its members, employees, employers and shareholders. If the veil of incorporation is removed both bodies would be treated as a single legal entity. Just like in any state of affairs we have a conqueror and a loser, the Court often founds itself into the quandary as whether to lift or not to lift the veil of incorporation to determine where the loss lie, more explicitly who will bear the burden of costs. The Court will either award an injunction; Gilford motor Company Ltd v Horne (1933), specific performance; Jones v Lipman (1962) or damages. An enhanced picture of Group companies consist of a parent A ltd which is the chief company and its two subsidiaries X ltd and Y ltd. I f A ltd runs its most perilous business through X ltd and in the event X ltd collapse or goes into liquidation and a person is injured while working, the question which arises is whether the parent company A ltd should be liable for its subsidiaries. In economic reality there is a sole business pertaining work through three different legal personalities. Yet again the question is should the veil be lifted or not. In Re A Company (1985) it was held that irrespective of corporate structure used, the veil will be lifted to achieve justice. The key case regarding parent and Subsidiaries Company is Adams v Cape Plc Ltd (1990). Its judgement has drastically narrowed the ability of the courts to lift the veil. Here the subsidiaries found in the US mined asbestos and when Adam while working in one of Cape Ltd subsidiaries was injured sought relief against the parent company fund in the UK. The Court of Appeal revised this complex area of law and concluded that the veil should be lifted i n three conditions. Primarily where the corporate structure is a mere faÃÆ' §ade concealing the true facts. Furthermore if an express agency relationship exists between a company and its shareholders or between a parent and subsidiary company in a group structure. Thirdly where the group of companies is in reality a single economic entity. The motive of the subsidiary company in Adams was to prevent tax and there were no express agency agreement since parent company had no control over the subsidiary company. Therefore, the Court didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t lift the veil of incorporation. If one of the above three issues are present the veil of incorporation will be lifted. Otherwise the Salomon principle applies. We has had statutory intervention under s.399 CA 2006 where parent companies have a duty to produce Group accounts and under s.409 CA 2006 they have to provide details of shares it holds in the subsidiaries and subsidiaries names and country of activity. Also s.993 CA 2006 introduces the criminal offence of fraudulent trading. Nevertheless the Court has always been keen and watchful in safeguarding the corporate veil. Sec 213-215 Insolvency Act 1986 deal veil lifting. Since the Corporate form was being used as an instrument of fraud namely fraudulent trading s.213 Insolvency Act 1986 came into play but the dilemma was that we had to prove intent which was difficult and attracted criminal charge of imprisonment and fine. S.213 of the Insolvency Act 1986 deals with situation where any business of the company carries intent to defraud and applies to everyone. The purpose of this section was to restrict fraudulent trading, nonetheless, the high standard of proof as required by the court negated its effect due to the possibility of a criminal charge arising. s.214 Insolvency Act 1986 on the other hand applies mainly to directors who had been negligent leading to the insolvency of the company for example in Re Produce Marketing Consortium Ltd (1989) the 2 directors were liable to pay  £75000 to the debts of the company since they didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t put the company in liquidation before it reached to the point of insolvency. Since Adams the Court has lifted the veil of incorporation in various state of affairs. For example in tort in Lubbe v Cape Plc (2000), the parent company owed a duty of care to anybody injured by subsidiary company in a group and in Chandler v Cape Plc (2011) duty of care has been breached by parent company. The point in tort is that a personal injury caused by a UK subsidiary operating in a jurisdiction with a developed country such as USA will not give rise to any liability on part of the parent company but a personal injury caused by a subsidiary of a UK company in an underdeveloped jurisdiction will. In addition, if the tort is deceit rather than negligent, Court will allow liability to flow to director or employee. In so far the court has extended the principle of lifting the veil of incorpo ration in various new situations which arose and the Court was left to the choice of whether to lift the corporate veil or not. Location Title Words Matched Match (%) Unique Words Matched Unique Match (%) Documents found to be plagiarised https://www.icaew.com/en/technical/legal-and-regulatory/company-law/directors-duties-and-derivative-actions Directors duties and derivative actions | Modernising UK 244 10 244 10 https://en.wikipedia.org/wiki/Wallersteiner_v_Moir_(No_2)Wallersteiner v Moir (No 2) Wikipedia, the free encyclopedia 45 2 45 2 https://quizlet.com/20863950/company-11-majority-rule-flash-cards/Company 11 : Majority rule flashcards | Quizlet 664 27 534 22 https://www.routledge.com/cw/revision2/p/company/Company Law Routledge Revision61 3 0 1 https://law.oxy.co/the-doctrine-of-foss-v-harbottle-94620/The doctrine of foss v harbottle Online law school 77 3 0 1 https://quizlet.com/30315857/company-law-shareholder-cases-flash-cards/Company Law Shareho lder Cases flashcards | Quizlet 31 1 0 1 https://www.legislation.gov.uk/ukpga/2006/46/part/11/chapter/1/enactedCompanies Act 2006 legislation 140 6 0 1 https://www.scribd.com/doc/82932029/Shareholders-Derivative-ClaimsShareholders Derivative Claims Scribd Read Unlimited Books 47 2 0 1 https://www.publications.parliament.uk/pa/ld200506/ldbills/098/06098.110-115.htmlCompany Law Reform Bill [HL] 103 4 0 1 https://www.kenyalawresourcecenter.org/2011/07/majority-rule-foss-vs-harbottle-1843.html Kenya Law Resource Center: MAJORITY RULE ( Foss vs 64 3 10 1 https://www.mondaq.com/x/54792/Directors+Officers/A+Guide+To+The+Companies+Act+2006+Part+1 A Guide To The Companies Act 2006 Part 1 Corporate 95 4 0 1 https://www.lawteacher.net/free-law-essays/business-law/development-of-statutory-derivative-actions-business-law-essay.php Development of Statutory Derivative Actions | Law Teacher 50 2 0 1 https://www.lees.co.uk/news/protection-for-minority-shareholders/Protect ion for minority shareholders Lees Solicitors 78 3 34 1 https://www.mondaq.com/x/131408/Directors+Officers+Executives+Shareholders/Minority+Shareholders+Protection+In+Cyprus+Remedies+Available Minority Shareholders Protection In Cyprus ÃÆ' ¢Ãƒ ¢Ã¢â‚¬Å¡Ã‚ ¬Ãƒ ¢Ã¢â€š ¬Ã…“ Remedies 17 1 0 1 https://www.scribd.com/doc/155477950/Book-by-Dignam-and-Lowry-Company-LawBook by Dignam and Lowry Company Law Scribd 613 25 49 2 https://falguni-moyeed.blogspot.com/2011/05/s260-of-company-act-2006-is-unnecessary.html S.260 of Company Act 2006 is an unnecessary piece of legislation. 198 8 0 1 https://quizlet.com/22921227/derivative-claims-flash-cards/DERIVATIVE CLAIMS flashcards | Quizlet 129 5 0 1 https://www.legal500.com/assets/images/stories/firmdevs/shareholders_protection.docwww.legal500.com 17 1 0 1 https://www.legislation.gov.uk/ukpga/2006/46/section/260Companies Act 2006 Legislation.gov.uk 48 2 0 1 https://www.out-law.com/page-8207Remedies where there is a breac h of directors duties 40 2 0 1 https://www.mondaq.com/x/52870/Corporate+Governance/New+Derivative+Action+May+Lead+To+Increased+Claims+Against+Directors New Derivative Action May Lead To Increased Claims Against 18 1 0 1 https://www.publications.parliament.uk/pa/cm200506/cmbills/190/06190.111-117.htmlCompany Law Reform Bill [HL] 114 5 0 1 https://www.scribd.com/doc/196444315/76768383-Company-Law-Guide76768383 Company Law Guide 613 25 0 1 Matching Content: 40%. Moreover in Prest v Petrodel [2013] seven companies held by Mr Prest a very wealthy man could be transferred to his wife upon dissolution of their marriage as ancillary relief during Matrimonial proceedings. While the defence of Mr Prest was that his companies should have separate legal entity, the Court of Appeal held that the corporate veil will be pierced in very limited circumstances. Firstly where there is a deliberate abuse of a corporate entity (i.e. to hide behind the corporate veil) for improper purposes a nd secondly the specific facts show that the assets are genuinely held on trust for a party to the proceedings. The reason why Mrs Prest succeeded in her claim was due to the special facts of her case. At various time Mr Prest tried to conceal the fact that the seven companies were held on trust for him. Moreover both he and the company failed to cooperate with disclosure allowed the court to infer that Mr Prest and the companies were attempting to hide the true beneficial owner of the properties. However it should be noted in this case, Lord Sumption sheds light on the nature and extent of the doctrine. He extracted principles which are concealment and evasion principles. In the first principle we have to investigate as to who are the à ¢Ã¢â€š ¬Ã‹Å"real actorsà ¢Ã¢â€š ¬Ã¢â€ž ¢ that is . the real controller of the company just like in Gilford Motors v Horne. In the latter principle, the Court pierces the veil to prevent a party from avoiding a legal obligation by virtue of the fac t that they have interposed a company in an attempt to defeat a right which will be enforced against them. To conclude with the question of whether to lift the veil of incorporation or not will depend on each and every case. The Court has always respected the legal personality of a company and will lift the veil in very limited conditions. The separate legal personality of the company has been established for more than a century, the decades that have intervened have encouraged a belief in this principle but have also allowed exceptions to the concept when lifting of this corporate veil is permitted for example in situations of fraud, or sham. Nevertheless the courts have the power to continue developing the law in this area when public policy requires it. It can be seen in Prest v Petrodel (2013) that a director can be liable to contribute to the debts of the company if he has been negligent in the company going into insolvent liquidation and did nothing to prevent that. The vei l will be pierced if subsidiaries have been created with motive of defrauding creditors or to prevent a transaction. Moreover, if the subsidiary company worked under the control of the parent company and there was an express agency agreement between the two such that the two are inter-linked. If tort is deceit instead of negligent liability will flow to employees or director. Furthermore, the Court wonà ¢Ã¢â€š ¬Ã¢â€ž ¢t be easily fooled if someone tried consistently to conceal facts which are of utmost importance for the Court. Thus there is currently the possibility of extension of the law at the courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢ discretion. My study of the law in this area leads me to the conclusion that the case for more radical reform of liabilities within groups has not been made. The law as it currently stands reflects the balance that is required between the needs of the economy and the needs of justice. Words: 1687 Bibliography Wikipedia University of Leceister (pdf note s) Lawteacher.net Corporatewatch.org.uk Secondary sources Recent developments of company law (UOL) Alan Dignam and John Lowry . In this category most specifically we refer to sham. In Gilford Motor CO ltd v Horne (1933), a former employee was bound by a contractual obligation not to solicit customers from his former employer after he left the job. To avoid the contractual obligation horne incorporate a company and solicit customers. The court found that it was in the interest of justice for the court to act as the new company was a sham. Similarly in jones v lipman the court held that company was a sham and was an attempt to avod a pre existing legal oblgation. the court gave an order for specific performance for the house to be transferred to the original purchasers. Company Law Textbook

Analysis Of Vladimir Nabokov s Short Stories - 4187 Words

Abstract Vladimir Nabokov’s short stories featured are Signs and Symbols, Bachmann and Terra Incognita. Signs and Symbols focuses on a young boy institutionalized with a morbid paranoia of the outside world and the impact this has on his elderly parents. Bachmann is about a genius composer whose only source of affection is of Madame Perov, whose infatuation is seen in her constant attendance of his piano recitals. Terra Incognito’s main character Vallià ©re and his companions are losing their minds and lives to strange hallucigenic fever in a remote country in the fictional country of Zonraki. Strong aspects of all three short stories focus on the alienation of each of the protagonists and the cause of this, either due to madness, great creativity or delusion. This link is forged between the three, which would have not been as obvious. 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Iago s Final Soliloquy As The Motive Hunting Of...

During Samuel Taylor Coleridge’s nineteenth century lectures on Shakespeare’s play Othello, Coleridge described Iago’s final soliloquy as the â€Å"motive hunting of motiveless malignancy.† Throughout the speech, Iago gives various reasons to rationalize his actions. He states that Othello slept with his wife, Othello gave Cassio the lieutenant position that Iago was next in line for, and Cassio and his wife had an affair. Each perceived injustice holds the potential to justify Iago’s actions but the flippancy in which each are stated and the fact that Iago is unable to pinpoint a singular cause for his desire for vengeance supports Coleridge’s claim that Iago is simply hunting for a motive to justify his malignancy. Coleridge asserts that despite the various reasons given, Iago is completely motiveless. He causes chaos for the sake of causing chaos. Iago’s lack of a reason for his destructive tendencies and the fact that he effects ev ery main character in the play, elevates him from a mere villain to a symbol of the unavoidable chaos that accompanies life. Shakespeare employs Iago as a symbol of anarchy as he wreaks havoc on every innocent character in order to demonstrate the only way to triumph over the inescapable uncertainty of life is through adopting a calm and logical mindset. In Act 1 scene III of the play, Shakespeare opens on a seemingly random and useless military discussion between the members of the Venetian counsel in order to present the correct way to

Trifles, By Susan Glaspell Essay - 1469 Words

Susan Glaspell’s one-act play Trifles is based on the murder investigation of John Wright. Minnie Wright’s isolation and the death of her canary are the major factors that led to the murder of her husband. Glaspell stresses the perceived supremacy of males when investigating the murder by giving the men lead roles in the investigation and by making fun of the â€Å"trifles† that the women are choosing to observe. It is ironic because the ordinary items observed by the women were thought of as â€Å"trifles† to the men, but these items would have actually have aided in solving the murder case. Glaspell uses various forms of irony and symbolism to emphasize the dominance of men, Minnie Wright’s state of isolation, and many other key aspects of the murder in her play Trifles. The title of the play Trifles is used as a symbol to describe the way that women are viewed in the eyes of men. At the time of the play, males viewed women as trifles. Trifles are described as items that are of little importance or significance (Wakefield). The title could also be used as a symbol to signify the importance of the so-called â€Å"trifles† that the women were studying during the murder investigation. It is quite ironic because the common items observed my the women were thought to be useless to the men, while after combining further information about the murder investigation, these items would have been key to solving the case. Although they help Mrs. Wright by hiding any items that could haveShow MoreRelatedTrifles, By Susan Glaspell Essay2136 Words   |  9 Pagesprimarily of a domestic nature. Trifles by Susan Glaspell indicates that a man’s perspective is entirely different from a woman’s. The one-act play, Trifles, is a murder mystery wh ich examines the lives of rural, middle-aged, married, women characters through gender relationships, power between the sexes, and the nature of truth. 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Starwood Hotel Profile - 2561 Words

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New England vs. The Colonies Free Essays

Colonial Times than In the present. It was hard choice made by many European settlers when considering to what colony to go to. They had to choose between the Middle or Southern colonies along with New England. We will write a custom essay sample on New England vs. The Colonies or any similar topic only for you Order Now Each colony had certain, desirable features and characteristics that these settlers had to take into account. However, those that chose to reside in the New England colonies were the most fortunate of the colonists in terms of living standards and morals for a series of reasons. Also, these living standards apply to most people groups at the time. New England’s colonies were Rhode Island, Massachusetts, Connecticut, and New Hampshire. The New England colonies were most pleasant to live in partially due to the nature it was gifted with. The pristine environment was healthy to live in as it contained an immense, sprawling forest. (Amounts) This was also supplemented by the fact that it had great access to the coast. (Alicia) It was not afflicted by disease like the other colonies because of a cooler climate and naturally occurring clean water. Alcohol) A notable, Immigrant reverend named Francis Higgins commented on the matter. He stated For a sip of New England’s air is better then a whole draft of old England’s ale†. (Kennedy, pig. 71) One other motive that New England was superb In living conditions is its favorable political circumstances. One of the earliest precursors of American democracy was present in the Massachusetts colon y which is generally conceived as positive by most. The Massachusetts colony was self-governed by religious persons. Amounts) Only male. Protestant church members were allowed to participate In government, but at least tyranny was less of an issue. (Amounts) The great Thomas Jefferson awe one of the government meetings as â€Å"the best school of political liberty the world ever saw†. (Kennedy, pig. 73) New England was a more religiously tolerant group of colonies compared to other areas of North America. Puritans founded the Massachusetts colony for the purpose of establishing a place that offers more religious freedom. This was a way to get away from the Intolerant church of England In the British Isles. To escape Puritan ideology at the time, a person could move to the Rhode Island colony. Rhode Island was founded by a settler named Roger Williams where anyone can worship freely. It harbored many people, including the famous Anne Hutchinson, who would be persecuted in other colonies simply because of their beliefs. (Amounts) New England was the epicenter of The Great Awakening which benefited the area. This was due to the preaching of a famous preacher named Jonathan Edwards. This was spiritually refreshing for Christians which composed the majority of the population. Education developed at an increased rate and was concentrated in New England. Many top American universities Like Harvard were founded in the colonies. (Kennedy, pig. 87) The colonies of New England bore an economy that was stable, profitable and England provided an extremely high availability of lumber. This made lumber a major export and caused New England to be an important source of ships. Innumerable homes were also made with this lumber. The coast provided a gargantuan supply of fish, especially cod for which New England is well known for. Perhaps most importantly, New England had a drastically proportion and profit of the use of human slave labor. (Wisped) If an English person during the 17th and 18th centuries was wary of these facts, hen they would easily deduce that New England was the best colony to emigrate to. The factors dictating this choice would constitute of New England’s superior education and health, lowered dependence on human slaves, religious and political freedom and natural features. New England still draws people in due to its features. It is the home of the world’s highest educational and beauty. North America was arguably more of a land of opportunity during Colonial Times than in the present. It was hard choice made by many European settlers when considering to what colony to go to. They had to choose between the Middle or Southern colonies along with New England. Each colony had certain, desirable features and characteristics that these settlers had to take into account. However, those that chose to reside in the New England colonies were the most fortunate of the colonists in terms of living standards and morals for a series of reasons. Also, these living standards apply to most people groups at the time. New England’s colonies were Rhode Island, Massachusetts, Connecticut, and New Hampshire. Climate and naturally occurring clean water. (Alicia) A notable, immigrant reverend named Francis Higgins commented on the matter. He stated † For a sip of New One other motive that New England was superb in living conditions is its favorable Only male, Protestant church members were allowed to participate in government, of establishing a place that offers more religious freedom. This was a way to get away from the intolerant Church of England in the British Isles. To escape Puritan universities like Harvard were founded in the colonies. (Kennedy, pig. 87) more moral than colonies found elsewhere on the continent. The vast forests of New It is the home of the world’s highest educational and beauty. How to cite New England vs. The Colonies, Papers

Research Proposal Developments and Evaluation

Questions: 1.What is/are the research question/s?2.What is the proposed rationale/contribution?3.What is the methodology?4.What are the primary methods utilised?5.What kind of sampling approach is used?6.How were the results presented?7.What ethical considerations were documented? Answers: 1. The article on Social integration of Australian Muslims primarily focuses on understanding the social issues that are faced by the Muslims in Australia. Hence, the major research question is based on social issues about Islam that are explained by the Muslim leaders of Australia and the actions that are undertaken by these leaders to resolve the problems (Sohrabi and Farquharson, 2016). According to the leaders, the media misleads the perceptions of the public by interacting biased and distorted narratives. Hence, the primary research question is what are the social issues related to Muslims in Australia and how does the Muslim leaders in neutralise the issues of social misleads in Australia (Sohrabi and Farquharson, 2016)? Evaluation: According to Maggi Walter (2013), social research is differs to a scientific and management research through the context of questions asked in the study. It is important for a social research to ask questions that brings up any social issue that are taking place in the society or community. Walter says that social research is about seeking answer and investigating social questions that people ask about the real world. Considering the fact, it can be seen that the article is up to mark that asks a social question, what are the social issues related to Muslims in Australia and how does the Muslim leaders in neutralise the issues of social misleads in Australia? Hence, the research question helps to known about the social status of the Muslims in Australia and how the Muslim leaders deals with the issues of racism, injustice and terrorism status in the Australian state (Kelly, 2016). 2.Article: The identified article shows the Australians support towards multiculturalism and migration. Conversely, the anti-Muslim sentiments in the case of the Muslim migration have been largely defined showing evidence such as media disclosures (Sohrabi and Farquharson, 2016). Meanwhile, anti-Muslim persistent of prominent Australian leaders has been reconciled in the article leading to humiliation, injustice and racism towards the Australian Muslims. Admittedly, the role of the public has been identified through the article as the social public has not largely derived from the misleading information about the Muslim actions (Sohrabi and Farquharson, 2016). Precisely, the article talks about Muslim integrity if the media has replaced the dehumanising images about the Muslim community. Moreover, through the identification of social relationship, the study adopts dramaturgical perspective to judge the position of the individuals from sensitive point of view. As quoted in the study, Using the imagery of drama, he took advantage of a panoply of theatrical terms such as props, script, front and back stages, role, scenario, performance and character to explain the dynamics of presentation of self in face-to-face interactions, it is quite clear that the implications of the leaders have delivered dynamic roles of social integrity, trust and identity of people (Sohrabi and Farquharson, 2016). Evaluation: Predominantly, the research study represents the social integration of the Muslim community living in Australia under the leadership political leaders. Throughout the study paper, the authors, Sohrabi and Farquharson (2016) describes the role of the Muslim leaders to build up a political strategy for representing a clear image about Islam has been seemed to be missing in the article. However, according to the investigation, the authors identify that the Australian culture does not derive Muslim community as intolerant, arrogant and egotistical. Critically, the study argues about the foreign policy, labour market structure and cultural values of Australia under the social system integration (Forcese and Richer, 2013). Decisively, the Muslim leaders in Australia have found to be somewhat powerless influencing the dignity of the minority group within the country (Kelly, 2016). Furthermore, through the research study, authors describe the tolerant, law-abiding and peaceful li ving standards of Australian Muslims. Moreover, through the interviews of the Muslim leaders, Sohrabi and Farquharson (2016) identify the unfair and detrimental media representation about the Muslim community living in Australia. 3. Article: Considering the article on Social integration of Australian Muslims: A dramaturgical perspective by Sohrabi and Farquharson (2016), it can be seen that a dramaturgical model has been utilised to collect data and conduct the analysis. The article mainly focuses on the interaction with thirty Muslim leaders in Australia conducted in the form of direct interviews. Most of these leaders hold a good position in the Australian Muslim Community. The research has been conducted on a qualitative basis that presents the findings in a thematic manner. The data has been collected by conducting in-depth interviews of thirty Muslim Leaders who live in Sydney and Melbourne during 2010 and 2011 (Sohrabi and Farquharson, 2016). The article also presents the name of the participants in the list presented in the appendix. The interview has been conducted in an interactive way in which the participants are asked few questions and a discussion has been made on the given topic. The article sho ws that most of the participants were integrationist who worked for the welfare of the Muslim community in Australia. Integrationists are the people who believe in and support any social integration. They work for the social benefit of the community. Hence, the feedbacks of the participants have been used in context to the research question to present the direct thoughts of the Muslims living in Australia. On the other hand, the research can be termed as descriptive in nature that provides additional information on the chosen field of study. Evaluation: Considering the methodology used in the research, it can be seen that the authors have utilised the dramaturgical model of research study (Goffman, 1959). Goffman (1959) first presents a detailed analysis and description of a meaning and process in a mundane interaction. It is a process of conducting an analysis by interacting with different people belonging to a same field of study. Dramaturgical model is primarily used in social research to present the thoughts of the people regarding any social issues going on in the community. According to Glazkov (2016), it is a process of interacting with people to get information about the social matters and observe their thoughts to present the findings in a dramaturgical manner. In the article, the interviews are conducted by interacting with the participants in a discussion manner and findings are transcribed and analysed thematically (Stone, 1957). The research is conducted in a manner of performance in which the participants p layed their character according to the role and scenario. Walter (2013) says that dramaturgical perspective is one of the most suitable ways of conducting a social research that helps to present the findings as per the current view of the social volunteers. On the other hand, the methodology shows that the research has been conducted in a descriptive way in which more information can be added to the field of social issues among Muslims in Australia (Somekh and Lewin, 2005). The research is mainly based on qualitative analysis in which the research questions are answered to present a solution to the social issues. Hence, the Dramaturgical method has been well used in the study to provide realistic thoughts of the social activist in the country. It increases the reliability of the findings and makes reader aware of the actual facts in the community. 4. Article: The primary methods that are utilised in the article are the interviews that were conducted to collect primary data from the leading socialist Muslims of Sydney and Melbourne. It can be seen from the article of Sohrabi and Farquharson (2016), that most of the participants were integrationist who actively plays their role in improving the current status of the Muslims in Australia. In other words, the Muslim leaders chosen for the collection of data were the active members of the Australian Muslim Community who promote, encourage and advocate the social integration of the Muslims in the society. Hence, the primary sources of data were selected keeping in mind their professional backgrounds and social activities (Selltiz, 2009). Each interview was conducted for around 40 minutes in which the participants were presented with different themes on integration of Muslims in Australia. The participants were asked to present their views and understanding of the problems (Sohrabi a nd Farquharson, 2016). On the other hand, the participants were also asked to present the activities they undertake to mitigate such social issues in the community and society. Evaluation: Precisely, the identified primary methods used in the article are truly effective to evaluate each of the result of the interviews. Through the identification of the primary data received from the interview sessions, the role and responsibility of the leaders have been noted as a source of research data to evaluate how the leaders have played their part in promoting the peaceful mindset of Islamic community (Tahe and Laeheem, 2013). Also, the different approach of integrationists and isolationists has been identified through the primary data collection methods. Admittedly, the review of the interview outcomes has represented the everyday conflict situations of the Islamic community living in Australia that is one of the major benefits of the primary method (Mansouri and Lobo, 2011). 5. Article: As the sampling approach is an essential part of a research study, this particular research case determines significant sampling technique, to say the least. From the study, it is quite clear that in-depth interviews were conducted with well-known Muslim leaders during the period of 2010 and 2011 (Sohrabi and Farquharson, 2016). On basis of the process, the sampling approach has been identified as stratified sampling method to understand the orderly stance of the sub-groups included in the investigation (Stuart and Cochran, 2013). Precisely, the sub-groups included herein were miscellaneous ethnic and political leader groups belong to Muslim religion in Australia. On the other hand, in sampling secondary resources such as the internet has been taken into consideration to produce the best data collection suitable for the research study (Boddy and Dominelli, 2016). Conveniently, majority of the study participants has been recognised as Australian-born or brought up Muslims in Australia. Meanwhile, stratified sampling method has helped to identify the social integration of the participants regarding to the broader perspective. With different knowledge, political views and experience level, the identified thirty interviewing correspondents were asked to reflect their ideas and concepts on the given sections in order to gather compatible data regarding democracy, culture and social responsibility. Clearly, the sampling technique has been issues to promote broader composition of social integration. Evaluation: On a positive note, the research study has identified significant Muslim people so that their respective social work has been featured in the article. Precisely, most of the selected interviewers have been designated in the higher levels of media working for the social benefits of the Muslim community living in Australia. Through the interview session, it has been identified that most of the leaders are integrationist by nature. Through the media interactions, the leaders have influenced the non-Muslim community to understand the peaceful mindset of the Muslim. On this note the sampling was absolutely significant (Tahe and Laeheem, 2013). Secondly, in sampling approach out of the thirty candidates, eighteen has been male and rest of the twelve interviewers are female candidates. On this regard the sampling for the study includes opinion according to the gender equality. 6. Article: Throughout the entire research, most of the Muslim leaders have been identified as integrationist whereas some of the leaders are found to be isolationists. The integrationist leaders are quite clear about their views promoting Islam and peace through media. On the other hand, isolationist Muslim leaders have seemed to decline the thought of social integration (Hjelm, 2011). Although the minority of Muslim leaders are identified as isolationist, it shows negative intents of the leaders to the larger audience. In terms of broader perspective, descriptive analysis of the leadership thought and ideas have been presented as the result outcome to influence the non-Muslim community in a positive way. Evaluation: In terms of evaluation of the article, the reporting of identified data has been produced in a strategic way to show how majority of the Muslim leaders in Australia have performed their roles and responsibilities. Moreover, the outcome of the research has verified the attempts of the integrationist Muslim leaders to build up a Muslim identity according to the Australian culture (Sohrabi and Farquharson, 2016). Evidently, the outcome of the research article shows how the leadership has changed the mindset of the Muslim community towards non-Muslim Australians enhancing communication standards and societal benefits. Clearly, a peaceful image of Muslim community and their intention have been briefed throughout the study. 7. Article: Both the political and collective aspects associated with the Muslim community have been considered to conduct the study. Precisely, the respondents of the interview have been given the options to use either their real name or pseudonyms (Sohrabi and Farquharson, 2014). Meanwhile, the secrecy of the respondents has been kept secret following the ethical dignity. In addition to that, the alternative peaceful image of the Muslim life has been promoted to the non-Muslim community of Australia showing the symbolic feature of Islam. Thus, the ethical role of the Muslim leaders has been highlighted throughout the study paper (Hjelm, 2011). Apparently, the research does not describe the hostile climate of the Muslim communitys everyday life due to ethical background. Evaluation: In order to conduct the research, there have been issues regarding Muslim activism attached to the role of the Muslim leaders in enhancing conflict situation. For ethical basis, the outcome has been restricted to some extent. However, the research on integrationist Muslim leaders has been depicted in the research outcome to show the misleading information of the news channels and Australian media (Jupp, 2001). Typically the research has documented that the Muslim leaders have participated in the media interviews to denounce terrorism and hostility condemning the activities. Meanwhile, such attributes may ethically inspire the non-Muslim community to identify the peaceful mindset of Muslims. References Boddy, J. and Dominelli, L. (2016). Social Media and Social Work: The Challenges of a New Ethical Space.Australian Social Work, pp.1-13. Forcese, D. and Richer, S. (2013).Social research methods. Englewood Cliffs, N.J.: Prentice Hall. Glazkov, K. (2016). Erving Goffmans Gaming Concept of Everyday Life: Between Symbolic Interactionism and Ethnomethodology.RSR, 15(2), pp.167-191. Goffman, E. (1959). The Presentation of Self in Everyday Life. New York, Penguin. Hjelm, T. (2011).Religion and social problems. New York: Routledge. Jupp, J. (2001).The Australian people. Cambridge [England]: Cambridge University Press. Kelly, A. (2016).Social Research Methods. University of London International Programmes. Mansouri, F. and Lobo, M. (2011).Migration, citizenship, and intercultural relations. Farnham, Surrey: Ashgate. Selltiz, C. (2009).Research methods in social relations. [New York]: Holt. Sohrabi, H. (2015). Identity and Muslim leadership: the case of Australian Muslim leaders.Contemporary Islam, 10(1), pp.1-16. Sohrabi, H. and Farquharson, K. (2014). Australian Muslim leaders and normalisation discourses.Ethnicities, 15(5), pp.633-651. Sohrabi, H. and Farquharson, K. (2016). Social integration of Australian Muslims: A dramaturgical perspective.Journal of Sociology, 52(2), pp.387-402. Somekh, B. and Lewin, C. (2005).Research methods in the social sciences. London: SAGE Publications. Stone, G. (1957). The Presentation of Self in Everyday Life. Erving Goffman.American Journal of Sociology, 63(1), pp.105-105. Stuart, A. and Cochran, W. (2013). Sampling Techniques.Econometrica, 31(4), p.773. Tahe, H. and Laeheem, K. (2013). The Causes of Reduction of the Role in Youth Management According to the Islamic Way among Muslim Leaders in the Three Southern Border Provinces.Asian Social Science, 9(17). Walter, M. (2013).Social research methods. 3rd edition. Australia, Oxford Press University.