Commission of Responsibilities

The Commission on the Responsibility of the Authors of the War and on Enforcement of Penalties was a commission established at the Paris Peace Conference in 1919. Its role was to examine the background of the First World War, and to investigate and recommend individuals for prosecution for committing war crimes.
Background.
During the First World War, the Allied governments had decided to try defeated leaders whom they considered responsible for violations of international law and the laws of war. For that purpose, it was decided to establish an expert committee to make recommendations to that effect. Following the conclusion of the Armistice in November 1918, preparations began. The defeated German government officially concurred with the initiative on grounds that:
A complete truthful account of the world conditions and of the negotiations among the powers in July 1914 and of the steps taken at that time by the several governments could and would go far toward demolishing the walls of hatred and misconstruction erected by the long war to separate the peoples.
In addition, the German government proposed the establishment of a neutral committee of experts to study the matter. The Allied governments refused, claiming that:
they [the Allied governments] do not consider that the German proposal requires any reply as the responsibility of Germany for the war has been long ago incontestably proved.
Composition of the Commission.
The commission was established at the conference plenary session of 25 January 1919, and consisted of representatives of the five major Allied powers – the US, the British Empire, France, Italy, and Japan – with the addition of Belgium, Greece, Poland, Romania and Serbia (later: Kingdom of Serbs, Croats and Slovenes). Its members were as follows:
USA:
British Empire:
France:
Italy:
Japan:
Belgium:
Greece:
Poland:
Romania:
Serbia (later: Kingdom of Serbs, Croats and Slovenes):
The Commission was divided into three sub-commissions as follows:
Recommendations made by the Commission.
Majority opinion.
The Commission submitted its report on 29 March 1919. It concluded that blame for the war lay in the first instance with the governments of Germany and Austria-Hungary, and secondly with those of Bulgaria and Turkey. It recommended the establishment of an additional commission for a more exhaustive study of the alleged crimes of the defeated powers. It further recommended the establishment of an international tribunal for the prosecution of suspected war criminals, with no immunity from prosecution even for defeated heads of state. It recommended that the tribunal should consist of 22 judges, three from each of the five major powers and an additional six from other countries.
Dissenting opinion by the US delegation.
The US delegates submitted their own opinion on 4 April 1919, expressing their reservations on the report. They suggested refraining from prosecuting heads of state, and focusing instead on lower levels of the government and military. They also suggested that defeated leaders or commanders should not be charged with acts not considered criminal at the time of their commission, i.e. that rules of conduct should not be imposed retroactively. They also argued that there should not be a permanent international tribunal for war crimes, but that, following any future war, such a tribunal should be established by the governments of the nations directly affected.
Dissenting opinion by the Japanese delegation.
On the same day the US delegation submitted its minority opinion, the Japanese delegation submitted its own reservations. The Japanese delegation's main reservation was about the demand to indict heads of state for violations.
Legacy of the Commission.
The Commission's recommendations were not carried through at the time. The proposed international tribunal for war crimes was not established, because of the refusal of the German government to cooperate. Instead, a few German individuals accused of war crimes were tried in 1921 at the Leipzig War Crimes Trials by the German authorities themselves. However, the recommendations did bear fruit in the longer term. Following the Second World War, two international Allied tribunals were established in Nuremberg and Tokyo to try German and Japanese leaders accused of war crimes. The demand for a permanent tribunal for crimes against humanity continued even after those tribunals had been dissolved, leading eventually to the establishment of the International Criminal Court in 2002.


Gavin MacKenzie

Gavin MacKenzie is a Canadian lawyer and former Treasurer of the Law Society of Upper Canada. He works as a lawyer and partner at MacKenzie Barristers, a boutique litigation firm in Toronto, Ontario that he co-founded with his daughter, Brooke. MacKenzie's practice focuses primarily on civil appeals and professional liability litigation.
Early life.
MacKenzie grew up in Woodstock, Ontario. He attended the University of Western Ontario, studying journalism and political science, and graduated with a Bachelor of Arts. degree in 1972. He graduated from Osgoode Hall Law School in 1975.
Legal career.
MacKenzie was called to the Bar of Ontario in 1977.
MacKenzie has worked for a variety of large firms in Toronto, practicing civil litigation. In 1993, he published "Lawyers and Ethics: Professional Responsibility and Discipline". He has written columns for The Law Times ("The Profession") and the Canadian Bar Association's National Magazine ("Conduct Becoming"). He has also taught at Osgoode Hall Law School as an adjunct professor, teaching legal ethics and professional responsibility.
MacKenzie was an elected bencher of the Law Society from 1995 to 2008. He has also been honoured by induction as a Fellow for the American College of Trial Lawyers. He has served as chair of the Ontario Law Association's Library Co. Inc., and has chaired the Law Society's Professional Regulation Committee and Strategic Planning Committee. In February, 2006, he was elected Treasurer, the highest position in the society, which he held until June, 2008. He presented a third option to address the issue of articling as a requirement to become a lawyer in Ontario.
Awards and Honours.
In 2010, MacKenzie was awarded an honorary Doctor of Laws degree from the Law Society of Upper Canada.


Morell-Mermaid

Morell-Mermaid was a provincial electoral district for the Legislative Assembly of Prince Edward Island, Canada. Created from mostly 2nd Kings and parts of 3rd and 5th Kings, in 1996. It was named Morell-Fortune Bay from 1996 to 2007.
Members.
The riding has elected the following Members of the Legislative Assembly:


Simon Kaiser

Simon Kaiser (24 October 1828, Biberist – 27 March 1898) was a Swiss politician and President of the Swiss National Council twice (1868/1869 and 1883/1884).


Mackenzie South

Mackenzie South is a former territorial electoral district, that elected members to the Northwest Territories Legislative Assembly in Canada.
The electoral district covered the communities of Fort Smith, Hay River, Pine Point, Fort Resolution, Talston River, Snowdrift, Fort Reliance and Wynn's Sawmill.


Territory of Orleans

The Territory of Orleans or Orleans Territory was an organized incorporated territory of the United States that existed from October 1, 1804, until April 30, 1812, when it was admitted to the Union as the State of Louisiana.
History.
In 1804, all of the Louisiana Purchase south of the 33rd parallel became the Orleans Territory, and the remainder became the District of Louisiana. (The District of Louisiana was later renamed the Louisiana Territory; and still later, when the Orleans Territory became the State of Louisiana, the Louisiana Territory was renamed the Missouri Territory.)
The Organic Act of 1804, passed on March 26 for October 1 implementation, also created the United States District Court for the District of Orleans—the only time Congress has ever provided a territory with a United States district court equal in its authority and jurisdiction to those of the states. Congress also established the Superior Court for the Territory of Orleans whose three judges were the top territorial court.
On April 10, 1805, the Territorial Legislature organized 12 counties (starting from the southeast corner moving west and north): Orleans County, LaFourche County, German Coast, Acadia County, Iberville County, Attakapas County, Pointe Coupée County, Opelousas County, Rapides County, Concordia County, Natchitoches County, and Ouachita County.
The area that later became the Florida Parishes on the east side of the Mississippi River was not included in Orleans Territory at this time, as it was in the Spanish territory of West Florida. This area was formally appended to the territory on April 14, 1812, after having been annexed forcibly by the U.S. in 1810, although Spain did not formally relinquish any of West Florida until 1821. The western boundary with Spanish Texas was not fully defined until the Adams–Onís Treaty was negotiated in 1819. A strip of land known as the Sabine Free State just east of the Sabine River served as a neutral ground buffer area from about 1807 until the treaty took effect after ratification in 1821.
The Orleans Territory was the site of the largest slave revolt in American history, the 1811 German Coast Uprising.
In the 1810 United States census, 20 parishes in the Orleans Territory reported the following population counts:
Leaders and representatives.
William C. C. Claiborne was appointed Governor of the Orleans Territory; he held this position throughout the territorial period. Later he became the first Governor of the state of Louisiana.
There were two Territorial Secretaries, James Brown (1804–1807) and Thomas B. Robertson (1807–1811). Daniel Clark became the first Territorial Delegate to the U.S. Congress, in December 1806. Judge Dominic Augustin Hall was the U.S. District Judge of the Territory.
Judges of the Superior Court were John Bartow Prevost (1804–1808), Ephraim Kirby (1804) (died en route to New Orleans), Peter Stephen Du Ponceau (1804) (declined President Thomas Jefferson's appointment), William Sprigg (1805–1807), George Mathews, Jr. (1805–1813), Joshua Lewis (1807–1813), and Francois Xavier Martin (1810–1813).


Edmonton Mill Woods

Edmonton Mill Woods is a federal electoral district in Alberta, Canada, that has been represented in the House of Commons of Canada since 2015.
Edmonton Mill Woods was created by the 2012 federal electoral boundaries redistribution and was legally defined in the 2013 representation order. It came into effect upon the call of the 42nd Canadian federal election, scheduled for October 2015. It was created out of the electoral district of Edmonton—Mill Woods—Beaumont.
Members of Parliament.
This riding has elected the following members of the House of Commons of Canada:


Richard Morefield

Richard Henry Morefield (September 9, 1929 – October 11, 2010) was an American diplomat who served in the United States Foreign Service. He was one of the 66 staff members at the American embassy in Tehran who were taken captive by a militant Islamist student group called the Muslim Student Followers of the Imam's Line on November 4, 1979, in what became known as the Iran hostage crisis. He was one of 52 Americans who were held as a hostage for 444 days, until negotiations for the remaining captives being held hostage were concluded with the signing of the Algiers Accords on January 19, 1981, with their release coming the following day.
Early life and education.
Morefield was born on September 9, 1929, in Venice, California and grew up in San Diego. His college background focused on history, earning his undergraduate degree in the subject in 1951 from the University of San Francisco. He served for two years in the United States Army, attaining the rank of first lieutenant and received his master's degree in 1954 from the University of California, Berkeley after completing his military service. He joined the United States Foreign Service in 1956.
Iran hostage crisis.
On November 4, 1979, Morefield was in the American embassy in Teheran, where he was serving as the United States consul general to Iran. After the embassy was surrounded by Islamist militant students, the building was taken over. He was able to send a group of five Americans away by car who were able to take refuge in the Canadian Embassy. Morefield was with a group of about two dozen employees who had tried to leave the embassy compound but were captured a few blocks away by a group of students and Revolutionary Guards. In all, 66 Americans were taken hostage with the group demanding that Mohammad Reza Pahlavi, the deposed Shah who had been allowed to enter the United States, be returned to Iran for trial. A group of 13 female and African-American hostages were released in the weeks after the seizure and a seriously ill hostage was released in July 1980, leaving Morefield among the 52 American captives who would ultimately be held for 444 days.
Morefield was one of a group of six Americans who was at first taken to a school in Tehran, where they were placed in a shower room and had rifles pointed at them, marking the first of three mock executions he would ultimately face. Returned to the embassy compound in December, Morefield was put in a windowless basement storage room that he had to share with eight other hostages, leaving him with only enough room to take two or three steps in any direction. He and his fellow hostages had little to do but play card games and checkers with each other. Morefield took up a regular exercise regimen, doing push ups, sit ups and jogging around his cubicle for an hour each day. He lost more than 30 pounds by the time he was released and joked that "if I'm smart, this might have added 10 years to my life".
After the Algeria Accords were signed on January 19, 1981, Morefield and the other captives were given medical examinations and were released the next day, placed on buses surrounded by crowds shouting "Bad, bad, America's bad" and leaving the country on an Algerian airplane. He called his wife after they landed in Germany and told her that "those people tried to break us", but that "we beat them". Morefield was reunited with his wife and children at Stewart International Airport on January 25. His wife recalled her disbelief that she was finally seeing her husband, saying "Until that moment, I really didn't believe it was over. Then, of course, I ran, too. We didn't say anything for several minutes".
After release from Iran.
Morefield was assigned to head the State Department's Office of Caribbean Affairs and was assigned to Mexico where he served as consul general in Guadalajara and as the economic counselor in the American Embassy in Mexico City, his final posting.
Amid reports in 2005 that newly elected President of Iran Mahmoud Ahmadinejad had been one of the student radicals involved in the embassy takeover, Morefield said he didn't recognize him as "I was not one of those on which they spent a lot of time". Years after his release he held no grudge against the people of Iran, telling an interviewer from the BBC in 2006 that "I cannot equate what I know of Iran and its culture with the militant students who held me for 444 days" calling the country "a society with a lot of different groups which can contribute to a new modern Iran if they're given the chance".
Morefield died at age 81 on October 11, 2010, in Raleigh, North Carolina due to pneumonia. He was survived by his wife, Dorothea, as well as by a daughter and four sons. His son Rick had been killed in 1976 by a gunman during a robbery of a Virginia restaurant. Morefield recalled that the experience of dealing with the death of his son had given him greater strength to make it through the hostage crisis.


Jamaican dollar

The Jamaican dollar (sign: $; code: JMD) has been the currency of Jamaica since 1969. It is often abbreviated to J$, the J serving to distinguish it from other dollar-denominated currencies. It is divided into 100 cents, although cent denominations are no longer in use as of 2018. Goods and services may still be priced in cents, but cash transactions are now rounded to the nearest dollar.
History.
The history of currency in Jamaica should not be considered in isolation of the wider picture in the British West Indies as a whole. See British West Indies dollar. The peculiar feature about Jamaica was the fact that it was the only British West Indies territory to use special issues of the sterling coinage, apart from the four-pence groat coin which was specially issued for all the British West Indies, and later only for British Guiana.
The earliest money in Jamaica was Spanish copper coins called "maravedíes". This relates to the fact that for nearly four hundred years Spanish dollars, known as pieces of eight were in widespread use on the world's trading routes, including the Caribbean Sea region. However, following the revolutionary wars in Latin America, the source of these silver trade coins dried up. The last Spanish dollar was minted at the Potosí mint in 1825. The United Kingdom had adopted a very successful gold standard in 1821, so 1825 was an opportune time to introduce the British sterling coinage into all the British colonies.
An imperial order-in-council was passed in that year for the purposes of facilitating this aim by making sterling coinage legal tender in the colonies at the specified rating of $1 = 4s 4d (one Spanish dollar to four shillings and four pence sterling). As the sterling silver coins were attached to a gold standard, this exchange rate did not realistically represent the value of the silver in the Spanish dollars as compared to the value of the gold in the British gold sovereign, and as such, the order-in-council had the reverse effect in many colonies. It had the effect of actually driving sterling coinage out, rather than encouraging its circulation.
Remedial legislation had to be introduced in 1838 so as to change over to the more realistic rating of $1 = 4s 2d. However, in Jamaica, British Honduras, Bermuda, and later in the Bahamas also, the official rating was set aside in favour of what was known as the 'Maccaroni' tradition in which a British shilling, referred to as a 'Maccaroni', was treated as one quarter of a dollar. The common link between these four territories was the Bank of Nova Scotia which brought in the 'Maccaroni' tradition, resulting in the successful introduction of both sterling coinage and sterling accounts.
In 1834, silver coins of threepence and three halfpence ( pence) were introduced, valued at  real and  real. The three-halfpence coins came to be called "quartiles" or "quatties". These in particular were used in church collections due to a feeling by the black population that copper coins were inappropriate for that purpose. Hence, they came to be called "Christian quatties".
In 1839, an act was passed by Parliament declaring that as of December 31, 1840, only British coinage would be legal tender in Jamaica, demonetizing all of the Spanish coins, with the exception of the gold doubloon which was valued at £3 4s. Coins in use were thus the farthing (d), halfpenny, penny, three halfpence (d), threepence, sixpence, shilling, florin (2s), half crown (2s 6d), and crown (5s).
The emancipation of the slaves in 1838 increased the need for coinage in Jamaica, particularly low-denomination coins, but the blacks were still reluctant to use copper. The solution was to use cupronickel, adopted in 1869. Pennies and halfpennies were minted for use in Jamaica, becoming the first truly Jamaican coins. Beginning in 1880, the farthing was also minted in cupronickel.
In 1904, the first government-authorized banknotes were produced in the denomination of 10s. Banknotes of £1 and £5 were also being circulated by chartered banks. In 1918, denominations of 2s 6d and 5s were authorized. The 2s 6d note proved to have a short life, being withdrawn in 1922. In 1940, the government bank began producing £1 and £5 notes.
In October 1960, the Bank of Jamaica was given the sole right to mint coins and produce banknotes in Jamaica. Their notes were released on May 1, 1961, in the denominations of 5s, 10s, £1, and £5.
On January 30, 1968, the Jamaican House of Representatives voted to decimalize the currency by introducing the dollar, worth 10 shillings, to replace the Jamaican pound. Coins and banknotes went into circulation on September 8, 1969. The introduction of a decimal currency provided the opportunity for the introduction of a complete Jamaican coinage as formerly, the coins (with the exception of the penny and halfpenny), were the same as those used in the United Kingdom. The reverse of the decimal coinage was designed by Christopher Ironside. These coins were in circulation from 1969 to about 1990.
From its introduction, as a result of elevated levels of inflation during the 1980s and especially the early 1990s, the Jamaican dollar has fallen from a peak of J$0.77 to US$1 in its first few years of circulation to around J$131 to US$1 as of July 2018.
The new Jamaican dollar (and the Cayman Islands dollar) differed from all the other dollars in the British West Indies in that it was essentially a half-pound sterling. All the other dollars either began on the US dollar unit or the Spanish dollar unit.
Coins.
At the time of the currency's introduction, 1969, coins of 1 cent (1.2 pence), 5 cents (6 pence), 10 cents (1 shilling), 20 cents (2 shillings), and 25 cents (2 shillings 6 pence) were produced. With the exception of a smaller bronze 1 cent, the compositions, sizes, and shapes of the coins were identical to those they replaced.
The 1-cent coin was changed in 1975 to a twelve-sided shape and aluminium composition. Decagonal 50-cent coins were introduced in 1976 to replace the 50 cent banknote, but production for circulation ceased in 1989, along with that of the 20 cents. In 1990, nickel-brass 1 dollar coins were introduced to replace the banknote of the same denomination. Nickel-plated steel replaced copper-nickel in the 5, 10, and 25 cent coins in 1991 with a smaller size and seven-sided shape for the 25 cent coin. In 1994, a round nickel-plated steel 5 dollar coin replaced its corresponding banknote, a smaller, seven-sided nickel-plated steel 1 dollar coin was introduced, and the 5 cent coin was abandoned. 1995 saw smaller, round copper-plated steel 10 and 25 cent coins. All non-current coins were demonetized in January 1997. A scalloped nickel-plated steel 10 dollar coin replaced the 10 dollar note in 1999 and a bimetallic 20 dollar coin with a nickel-brass ring and copper-nickel center was introduced in place of a 20 dollar banknote in 2000. All nickel-plated or copper-plated steel coins are magnetic.
All coins have the Jamaican coat of arms on their reverse.
Coins currently in circulation are as follows:
Banknotes.
On 8 September 1969, banknotes of 50 cents (5 shillings), $1 (10 shillings), $2 (£1), and $10 (£5) were introduced. The $5 note was introduced on 20 October 1970, followed by the $20 in June 1976, when the 50 cent note was replaced by a coin. $100 notes were added on 2 December 1986, followed by $50 notes on 27 July 1988. The $2 note was dropped in 1994, whilst the $1 note was replaced by a coin in 1990. In 1994, coins replaced the $5 notes and $500 notes were introduced. In 1999, $10 coins replaced notes, whilst, in 2000, $20 coins replaced the notes and $1000 notes were introduced.
Banknotes currently in circulation are:
The Bank of Jamaica introduced a $5000 bill into Jamaica's monetary system on 24 September 2009. It bears the portrait of former Prime Minister of Jamaica, The Honourable Hugh Lawson Shearer. On May 18, 2009, a specimen note was presented to the former Prime Minister's widow, Dr. Denise Eldemire-Shearer. Finance Minister Audley Shaw criticized the decision to introduce the banknote, saying that the introduction of such a banknote is a sign that the Jamaican dollar is losing value.
On November 15, 2010, the Bank of Jamaica issued a $50 commemorative note to celebrate its founding. The note is similar to its regular issue in design and security features, but the bank's logo printed in blue, with the words "50th anniversary" and "1960–2010" printed above and below the logo. The back of the commemorative note features the Bank of Jamaica headquarters building in Nethersole Place set against a background of morning glory blossoms. Both the commemorative and the regular issue note circulate in parallel.
In 2012, the Bank of Jamaica introduced a new family of banknotes commemorating the country's Golden Jubilee. The commemorative banknotes are similar to its regular issue banknotes, but on the obverse it features the "Jamaica 50" logo superimposed on the watermark on the front of each note. The unique image, which is normally on the reverse side of each note, has been replaced by a photograph of a group of children from Central Branch Primary School, from 1962. It formerly appeared on the $2 note, which was in circulation from 1969 to 1994.
Currently, the Jamaican banknotes are printed on a cotton material which has a relatively short life in the country's tropical climate and other circulation conditions, but the new notes will come on enhanced substrates.
The $100 note is printed on a material called "hybrid", a combination of a protected polyester film layered on a cotton fiber core. The $50, $500, and $1000 notes are printed on a varnished cotton substrate, that is, the traditional cotton treated with a varnish after the notes have been printed. Varnishing creates a moisture-proof layer to protect the banknotes against surface soiling and reduces the extent to which they will absorb moisture, contaminant particles and microorganisms. The $5000 note remains on a regular cotton substrate as the main security thread, "Optiks", is compatible only with the cotton based material.
The commemorative notes are released into circulation on July 23, 2012 and the new notes will circulate alongside the regular issue banknotes.
On March 24, 2014, the Bank of Jamaica issued a $50 note printed on the "Hybrid" substrate. In 2015, the Bank of Jamaica issued a $100 note dated January 1, 2014 on the "Hybrid" substrate.
The $1000 note features an image of the Jamaican Swallowtail, the largest butterfly in the western hemisphere which is also endemic to Jamaica.
Use outside Jamaica.
The Jamaican dollar was used not only by Jamaica, but also by the Cayman Islands and Turks and Caicos Islands, former dependencies of Jamaica, until 1972 and 1973 respectively. In 1972, the Cayman Islands stopped using the Jamaican dollar and adopted its own currency, the Cayman Islands dollar, while in 1973 the Turks and Caicos Islands replaced the Jamaican dollar as legal tender with the United States dollar legal tender.
Half Pounds.
In adopting the Jamaican dollar, Jamaica followed the pattern of South Africa, Australia, and New Zealand in that when it adopted the decimal system, it decided to use the half pound unit as opposed to the pound unit of account. The choice of the name dollar was motivated by the fact that the reduced value of the new unit corresponded more closely to the value of the US dollar than it did to pound sterling.


Review of the Labour Party in Scotland

The Murphy and Boyack review was a report compiled by Jim Murphy and Sarah Boyack on the future structure of the Labour Party in Scotland, in response to the landslide victory by the Scottish National Party in the 2011 Scottish Parliament election. The report was presented to party leader Ed Miliband in the autumn of 2011, and was subject to approval by the British Labour Party Conference.
The stated aim of the root and branch review was "to achieve an effective, modern Scottish Labour Party, better able to earn the trust of, and deliver for, the people of Scotland."
CLPs had until 9 September to submit final submissions to the review.
In August 2011 Tom Harris expressed an interest in standing in the election to be the next leader of the Scottish Labour Party, subject to the findings of the Murphy and Boyack review allowing MPs to stand.


Operation Alba

Operation Alba ("Sunrise" or "Dawn" in Italian) was a multinational peacekeeping force sent to Albania in 1997. Led by Italy, it was intended to help the Albanian government restore law and order during the Albanian Civil War.
Beginning in early 1997, the Albanian government lost control of much of their country, culminating in the desertion of many police and military units and the looting of their armories. The resulting chaos caused several countries to autonomously evacuate their nationals from Albania, which prompted concerns about the fate of others. The United Nations Security Council consequently adopted Resolution 1101 to establish an operation that would stabilize the situation. The Italian 3rd Army Corps assumed responsibility for the stop-gap mission as Operation Alba, the first multinational Italian-led Mission since World War II. The eleven nations that participated in this operation were Austria, Belgium, Denmark, France, Greece, Italy, Portugal, Romania, Slovenia, Spain and Turkey.
Causes of the intervention.
Operation Alba was launched in response to the serious social crisis that had followed the collapse of major pyramid schemes in Albania in early 1997. The loss of many Albanians' life savings invested in these schemes, in addition to dissatisfaction with political corruption and recent electoral irregularities, caused large parts of the country to rise in rebellion against the Albanian government. As governmental control and rule of law collapsed, widespread looting and violence broke out. Early operations were carried out by individual countries to evacuate their citizens, but Alba was launched in an effort to resolve more extensive issues. Italy in particular was determined to curb the migratory flow of Albanian refugees that threatened to reach alarming dimensions. Disaster struck on 28 March, when dozens of Albanian migrants perished in the Tragedy of Otranto. Expecting the possibility of having to resort to force to restore order in Albania, Italy took care to acquire a mandate of the United Nations, the support of the OSCE, and the participation of a number of allies; when this was accomplished, Operation Alba was launched.
Operations in Albania.
Beginning on April 15, 7,265 troops were deployed under the command of the operation - of which more than half were Italian nationals - and quickly restored order in Tirana. The primary objectives of the mission included apprehending criminals and collecting looted weapons, but in later months operation troops also helped retrain Albanian forces to modern standards. Operation Alba finally concluded in August, as the last troops were withdrawn from the country.


Djamila Bouhired

Djamila Bouhired (, born c. 1935) is an Algerian militant. Bouhired is a nationalist who opposed the French colonial rule of Algeria. She was raised in a middle-class family by a Tunisian mother and an Algerian father, having attended a French school in Algeria. She would go on in her youth to join the Algerian National Liberation Front (FLN) while a student activist. There she worked as a liaison officer and personal assistant of FLN commander Yacef Saadi in Algiers.
Biography.
Djamila Bouherid was born in a middle-class family in colonial Algeria. When she was still a student in a French school, she discovered her revolutionary spirit. When all the Algerian students repeated every morning "France is our mother", Bouhired would stand up and scream "Algeria is our mother!" Of course, she was punished for this by the principal. From this time, Bouhired was drawn to the revolutionary cause. Her brothers having already been involved with the underground nationalist struggle, Bouhired was quick to join and her profile would quickly rise in stature. During the revolution she worked as a liaison agent for the commander Saadi Yacef.
In April 1957, before a large planned demonstration in the Casbah, she was captured by the French and, she claims, tortured for information about that demonstration. She did not divulge any information under torture and reportedly repeated "Algeria is our mother" while being tortured (the information is based on her own account and cannot be independently verified). Despite all of this extreme torture, Bouhired maintains that she did not confess to any wrongdoing or reveal any confidential information about the FLN. According to Bouhired, the torture went on for a total of 17 days.
In July 1957 she was tried for allegedly bombing a cafe, alongside another Algerian freedom fighter, Djamila Bouazza, aged 19. The bomb killed 11 civilians inside. At the time the French lawyer Jacques Vergès, sympathetic to the cause of the Algerian nationalists, heard of her case and decided to represent her. In what would be a historic trial, Vergès waged a public relations campaign on Bouhired's behalf and accused the French government of themselves having committed the acts charged in his defense. Despite Vergès's efforts, Bouhired was convicted and sentenced to death by guillotine.
Vergès co-wrote a plea arguing that Bouhired should not receive the death penalty. Various protest groups formed throughout Algeria and abroad rallied to convince the government not to kill Bouhired. Most notably, princess Laila Ayesha of Morocco contacted the President of France at the time, René Coty, and asked that Bouhired be spared from the death sentence. After being spared, Bouhired served a prison sentence in the Reims prison until 1962. As the end of the war drew near, she was released along with many other Algerian prisoners.
Vergès claimed to have become a target of the French colonial government, which allegedly launched several failed assassination attempts against him, including a bomb placed in his apartment and another in his car. Bouhired and Vergès were married a year after Algeria's independence, by which point Vergès had converted to Islam and taken the first name Mansoor. The couple had two children, Meriem and Liess Vergès. Bouhired separated from Vergés in 1970, after 7 years together. She became chairwoman of the Algerian Women Association in independent Algeria, and was constantly at odds with then-Algerian President Ahmed Ben Bella.
Bouhired was one of the many women fighting for emancipation and equality in the newly independent Algeria. However, economic downfall and exponential population growth caused a rise in Islamic fundamentalism, which coupled with new laws allowing for a multi-party political system ultimately resulted in civil war. Equality for women was not a priority of the government throughout this period in Algerian history. Nonetheless, Bouhired will forever be known for her work not just for Algerian independence, but also for women's rights in Algeria and the Middle East.
Period of imprisonment.
Very few details about what transpired during her imprisonment can be independently confirmed. The only information available is what Bouhired and sources related to her have claimed afterwards. What she stated is that she was subjected to torture during her imprisonment and that the torture was not limited to her, that her brothers were also subject to torture, one of them having been tortured in front of their mother.
Present day.
Djamila Bouhired resides in the capital of Algeria, Algiers, and continues to be a militant for several causes of which she participates in protests and marches, including the 2019 Algerian protests.
In popular culture.
She was one of the trio of FLN female bombers depicted in the 1966 film "The Battle of Algiers". She was also depicted in the film "Jamila, the Algerian" (1958) by Egyptian director Youssef Chahine and in "Terror's Advocate", a documentary film about Jacques Vergès.


Te Tai Tonga

Te Tai Tonga is a New Zealand parliamentary Māori electorate, returning one Member of Parliament to the New Zealand House of Representatives. It was established for the 1996 general election, replacing Southern Maori. The current MP for Te Tai Tonga is Rino Tirikatene of the Labour Party.
Population centres.
Te Tai Tonga is geographically by far the largest of the seventy-one electorates of New Zealand, covering all of the South Island, Stewart Island, the Chatham Islands, all the islands in the Southern Ocean and a large part of the Wellington urban area, namely Wellington City as far as Churton Park, and Lower Hutt City south of Naenae and west of Wainuiomata. Besides Wellington, the main centres in Te Tai Tonga are Nelson, Christchurch, Timaru, Oamaru, Dunedin, Queenstown, and Invercargill.
As a Māori electorate, Te Tai Tonga overlaps with the sixteen South Island electorates, as well as Rongotai and Wellington Central, and parts of Ōhāriu and Hutt South.
Te Tai Tonga's size was marginally decreased after a review of boundaries in 2007, when the suburbs of Naenae and Taitā were moved into Ikaroa-Rāwhiti. The 2013/14 redistribution did not further alter the boundaries of the electorate. The 2019/20 redistribution adjusted the north-east boundary to align with the northern boundary of Hutt South.
The main iwi of Te Tai Tonga are Ngāi Tahu/Kāi Tahu, Kāti Māmoe and Waitaha, and in the North Island, Te Āti Awa ki Whakarongotai, Ngāti Toa Rangatira and Ngāti Poneke, that latter of which is not iwi in the traditional sense, but an urban pan-tribal grouping. The Chatham Islands was invaded by members of Ngāti Mutunga and Ngāti Tama, and their descendants live there today, alongside the indigenous Moriori.
History.
Te Tai Tonga was established for the 1996 general election, replacing Southern Maori which had existed since the first Māori elections in 1868. The 1996 election was the first to use the Mixed Member Proportional (MMP) voting system and a new formula for calculating the number of electorates, which resulted in an increase in the number of Māori electorates from four to five.
The main difference involves the separation of the Wairarapa and Hawke's Bay into seats wholly located in the North Island—initially Te Puku O Te Whenua, and since 1999 Ikaroa-Rāwhiti.
Whetū Tirikatene-Sullivan had served as Southern Maori's representative in Parliament since 1967—during the terms of five different governments and nine Prime Ministers. However, the New Zealand First Party challenger Tū Wyllie tipped her out of the seat in 1996, as sixty years of Labour Party control of the Māori electorates ended.
In 1999 New Zealand First lost its electoral footing after an unpopular term in office, firstly as junior government-coalition partner and then following an internal split in the party, with much of the party's original parliamentary caucus leaving the party ("waka-jumping") to prop up the government of Jenny Shipley (although Wyllie himself did not join the breakaway group). Along with a drop in the New Zealand First vote from thirteen to four percent nationwide came the return of the Māori electorates to Labour and the election of Mahara Okeroa to Parliament as the Labour Party MP for Te Tai Tonga.
A political difference of opinion between many Māori and the Labour Party emerged in 2004, when Helen Clark's Labour government introduced the Seabed and Foreshore Bill, claiming the coastline for the Crown and in the process providing the catalyst for the launch of the Māori Party (7 July 2004), which went on to win four of the seven Māori seats (but not the plurality of the party votes cast in those seats) at the 2005 general election. Te Tai Tonga did not form part of this electoral sea-change, with Okeroa's majority slashed from 8,000 to around 2,500 despite his facing two fewer contenders than in 2002.
Rahui Katene won the electorate for the Māori Party in the , defeating the incumbent. She was defeated after a single term; Rino Tirikatene, the nephew of Tirikatene-Sullivan, won the electorate in with a margin of 1,475 votes. He was returned in the 2014 and 2017 elections with increased majorities.
Members of Parliament.
Key
List MPs.
Members of Parliament elected from party lists in elections where that person also unsuccessfully contested the Te Tai Tonga electorate. Unless otherwise stated, all MPs terms began and ended at general elections.
Election results.
2011 election.
Electorate (as at 26 November 2011): 31,933
1999 election.
Refer to Candidates in the New Zealand general election 1999 by electorate#Te Tai Tonga for a list of candidates.


Walter Buser

Walter Buser (14 April 1926 – 17 August 2019) was a Swiss politician from the Social Democratic Party of Switzerland (SDP).
Biography.
Buser was born in Lausen, Switzerland, the son of a farmer. He studied at Bâle and at Bern, obtaining a doctorate in law in 1958. From 1950, he was a legal advisor and editor of Social-Democratic newspapers. From 1956 to 1962 he was chief editor of the "Socialist Federal House correspondence".
In 1965 he joined the federal administration and spent three years as head of the Legal and Information Service of the Department of Home Affairs. The Federal Council elected him Vice-Chancellor in 1968; in this capacity he was responsible for legal services and information throughout the federal administration. In 1977 he was appointed an Associate Professor of Public Law at the University of Basel, where he taught in particular the administrative law of the federation.
After the resignation of Chancellor Karl Huber in 1981, Buser campaigned against Joseph Voyame of the CVP and Hans-Ulrich Ernst of the SVP. He defeated his opponents and became the first Social Democratic chancellor. Buser introduced regular press conferences and expanded the Federal Chancellery to a staff office of the Federal Council. He also adopted electronic data processing for the Federal Chancellery. He resigned his post in 1991. Buser died on 17 August 2019 at the age of 93.


Menachem Mautner

Menachem (Menny) Mautner is the Daniel Rubinstein Professor of Comparative Civil Law and Jurisprudence at the Tel Aviv University, Faculty of Law and was Dean of the Faculty between the years 2000 and 2002. He obtained a J.S.D. from Yale Law School. Mautner teaches at Tel Aviv University courses in the areas of contract law, law and culture and multiculturalism.
Career.
Mautner was twice visiting professor at Michigan Law School, teaching courses on contract law and commercial transactions; twice visiting professor at NYU Law School, teaching courses on contract law and law and culture - in 1996 he was among the first 20 legal scholars from all over the world appointed by NYU Law School to its Global Law School Program; visiting professor at Cardiff Law School; visiting scholar at Harvard Law School; and visiting professor at Venice International University. He taught at Columbia University Law School in the spring term of 2009.
As a professor at Tel Aviv University Mautner initiated the Law Faculty's "Affirmative Action Program" that was later on adopted by all universities in Israel as part of their admissions programs. He also initiated the "Invitation to Law Program" for teaching law at elementary schools and high schools, particularly at poor communities.
As dean, Mautner led the most far-reaching curriculum change ever undertaken by the faculty, as well as a fourfold expansion of the clinical program of the Faculty. In the course of Mautner's tenure as dean, 8 new members were appointed to the faculty.
In 2007 he was invited to deliver a lecture at the Israel Academy of Sciences and Humanities.
Mautner was member of the Committee on the Preparation of Israel's New Civil Code (headed by Professor Ahron Barak, President of the Israeli Supreme Court). He headed the Experts Committee on Revision of Israel's Securities Law, Ministry of Justice. He was the Chairperson of the Public Commission on the Rights of Performing Artists, Ministry of Justice.
In 2006 Mautner was elected by the Senate of Tel Aviv University to serve on the Search Committee for electing the new president of the university. At Tel Aviv University, Mautner also headed the Committee on the Establishment of a University Press; he is currently the President of the Disciplinary Tribunal of the Academic Staff; he was member of the Disciplinary Tribunal of Students; he was member of the Central Appointments Committee. Since 2012, he has served on the advisory board of the Israeli think tank for common good politics, Shaharit.
Awards.
Mautner was awarded the "Zeltner Prize for Excellence in the Law", the Landau Prize for excellence in research (2018), and the Tel Aviv University Rector's Prize for Distinction in Teaching.
Works.
He is the author of "The Decline of Formalism and the Rise of Values in Israeli Law" (1993) – the most cited book on the far-reaching developments that have taken place in Israeli law in the past three decades.
Mautner is the author of "On Legal Education" (2002) – the book that paved the way to the change in the self-perception of Israel's legal academy from one functioning as part of the field of legal practice to an academy working in close interdisciplinary cooperation with other academic disciplines.
His book "Law and Culture" (361 pages) on the application of culture theory to law was published in April 2008 (Bar Ilan University Press).
His book "Law and Culture in Israel at the Threshold of the Twenty-First Century" (591 pages) was published in July 2008 (Tel Aviv University Press and Am-Oved Publishing).
His book "Human Flourishing, Liberal Theory, and the Arts: A Liberalism of Flourishing" was published in March 2018 (Routledge Studies in Social and Political Thought)
He edited four legal books, including "Multiculturalism in a Democratic and Jewish State" and "Distributive Justice in Israel".
Mautner published over 70 articles and chapters in books in Israel, the United States and Britain (including at the law reviews of Yale and Michigan universities) in the areas of contract law, law and culture and multiculturalism.
His article "'The Eternal Triangles of the Law': Toward a Theory of Priorities in Conflicts Involving Remote Parties", 90 Michigan Law Review 95-154 (1991), substantially influenced the case-law and the scholarship in the area of conflicts over rights in both Israel and the United States.
Lectures.
"How Should a Liberal State Treat Non-Liberal Cultural Groups? The Jurisprudence of Human Rights and the Standard of Human Dignity" in the Lecture Series of the United Nations Audiovisual Library of International Law


Mirabel (electoral district)

Mirabel is a federal electoral district in Quebec. It encompasses a portion of Quebec previously included in the electoral districts of Argenteuil—Papineau—Mirabel, Rivière-des-Mille-Îles, Terrebonne—Blainville and Rivière-du-Nord.
Mirabel was created by the 2012 federal electoral boundaries redistribution and was legally defined in the 2013 representation order. It came into effect upon the call of the 42nd Canadian federal election, scheduled for 19 October 2015.
Members of Parliament.
This riding has elected the following Members of Parliament:


Charlottetown-Parkdale

Charlottetown-Parkdale was a provincial electoral district for the Legislative Assembly of Prince Edward Island, Canada. It was created prior to the 2007 election from parts of Sherwood-Hillsborough, Parkdale-Belvedere and Charlottetown-Kings Square.
The riding consisted of most of the Parkdale neighbourhood and the St. Avard's and Belvedere neighbourhoods of Charlottetown.
Members.
The riding has elected the following Members of the Legislative Assembly:


Oleg Shenin

Oleg Semyonovich Shenin (; 2 July 1937 – 28 May 2009) was the leader of the Communist Party of the Soviet Union (Shenin), which should not be confused with the larger UCP-CPSU.
Shenin was a member of the Central Committee of the Communist Party of the Soviet Union; he was also a member of the Politburo and Secretariat from 1990 to 1991. During the Soviet coup attempt of 1991, he was a member of the group of CPSU CC members who tried to regain control of the country in order to re-establish the Soviet Union. He was later jailed for taking part in the events. He was given amnesty in 1994.
Shenin was the founding Chairman of the Union of Communist Parties - Communist Party of the Soviet Union (UCP-CPSU) from 1993, until he broke away from the Communist Party of the Russian Federation (CPRF) in 2001, after its leader Gennady Zyuganov refused to back the creation of a united Communist Party of Russia and Belarus. Zyuganov then succeeded Shenin as Chairman of the UCP-CPSU.
In September 1997, he met with North Korean leader Kim Jong-il in Pyongyang.
Presidential campaign.
Oleg Shenin applied to run as a presidential candidate for the 2008 presidential election but he was denied registration for failing to complete some paperwork correctly. According to Shenin, his candidacy was rejected because he did not provide a letter from his employer; he described this as an "idiotic pretext" because he had been retired for years.
Death.
Shenin died on 28 May 2009 aged 71 from a severe and prolonged illness.


Shadzha Batyrov

Shadzha Batyrov (1908 in Desht – 1965) served as General Secretary of the Communist Party of Turkmenistan.
His term lasted from March 1947 until 1950, when Balysh Ovezov succeeded him as General Secretary.


Jaime del Burgo Torres

Jaime del Burgo Torres (1912 – 2005) was a Spanish official, writer and a Carlist activist. He is noted mostly as a historian; his works focus on Navarre and the Carlist wars. As a public servant he is known as longtime head of Navarrese library network, regional Ministry of Information delegate and a governmental and self-governmental tourist official. As a Carlist he is acknowledged as moving spirit behind the Navarrese Requeté in the 1930s and as representative of the Carloctavista faction during early Francoism. He also wrote novels, poems and dramas.
Family and youth.
Del Burgo's ancestors can be traced back to the mid-19th century. There is close to nothing known about his grandafather, Victoriano del Burgo Palomar (1861-1931); some authors claim that he contributed to the Carlist cause. Victoriano lived in Pamplona and was married twice, first with Felipa Juanillo Pascual and then with Maria Magdalena Pascual Soria. The first marriage was childess, while the second one produced two sons. The older one was the father of Jaime, Eusebio del Burgo Pascual (1888-1970). According to one author he originated from the Navarrese town of Villava, according to another he was born in Pamplona. He was worker in the local paper-mill. and married a pamplonesa, Paula Torres Jacoiste (1887-1973). The couple settled in Pamplona. They had three sons and four daughters, all brought up in Traditionalist ambience; it is known that at the age of 45 Eusebio took part in street brawls, animated by the Carlists. They were also raised in fervently Catholic atmosphere, which at times bordered exaltation; Catholic visionaries used to run mystical sessions in the del Burgo family house in Pamplona.
Nothing is known about Jaime's early childhood; as a teenager he trained to become "" at unidentified school, possibly in Villava. He has never pursued a professional commercial career; during his adolescence years he was increasingly engaged in public activities, consuming more and more of his time. Del Burgo married Maria de las Mercedes Tajadura Goñi (1911-1999); her father, Federico Tajadura Arnaíz, was a military and rose to the rank of teniente. The couple had three children, Mercedes, Jaime Ignacio and Maria Antonia. Upon death Jaime left three children, thirteen grandchildren and four great-grandchildren. His son Jaime Ignacio del Burgo Tajadura was a conservative politician and the Prime Minister of Navarre (president of ) in 1979-1984. His grandson Ignacio del Burgo Azpíroz, otherwise a Pamplona lawyer, gained wider recognition as author of a historical novel. Another of his grandchildren, an entrepreneur Jaime del Burgo Azpíroz, married an older sister of Letizia Ortiz, becoming brother-in-law of Felipe VI of Spain.
Rebel.
Already as a youngster del Burgo engaged in the Carlist juvenile organization, Juventud Jaimista, in 1930 becoming secretary of the Navarrese branch of the organization; a year later he set up a local Carlist weekly "La Esperanza", trying his hand as an editor, manager and contributor. In 1931 he was among those founding provincial branch of the newly born national Carlist student association, Agrupación Escolar Tradicionalista. Remaining at its helm until the outbreak of the Civil War, del Burgo exercised enormous influence on the group and beyond, especially as in 1934 it launched its press tribune, the "a.e.t." weekly.
Initially Navarrese AET focused on juvenile activities like sport, leisure and outdoor, though they were increasingly flavored by cult of brotherhood, Carlist heroes, activism and virility, combined with anti-materialist spiritualism and a drive for change. A present scholar relates them to Sorel, Marinetti, T.S. Eliot and W. B. Yeats, also drawing parallels between aetistas and a millenarist Romanian ultra-Right Legion of Archangel Michael; another one points to fascist influence Indeed, the Sorelian thread manifested itself by social radicalism of Del Burgo and "a.e.t." The group departed from orthodox Traditionalist line, commiserating with masses of miserable beings pitted against the politically dominant potentates; they advocated limitation of wealth and regularization of profits. Contemptuous towards Carlist landowners like José Lamamié and Jaime Chicharro, the students supported Agrarian Reform, obstructed by feudal egoism of the odious grandees of grain. The group called for a Carlist Revolution aiming at a good clean-up of society, and was greeted with amazement by the older Carlist generation.
The rupturista stance of the aetistas had nothing in common with social radicalism of the republican Left. It remained extremely hostile towards the mass workers’ parties, their militancy to be confronted with vengeance and repaid with "bomb, dagger and fire", the cult of activism bordering the cult of violence. Strategy of Carlist leaders was denounced as ineffective; in 1934 del Burgo and the young, having declared themselves rebels fed up with legality, accused the old junteros of 3 years of inactivity, their only achievement having been the alliance with caciques and debris of the fallen liberal monarchy. AET despised parliamentary activities of the party elders and especially accommodation with the Alfonsists. The intemperate tone of the aetistas shocked the Navarrese Carlist authorities and made them call for moderation. As a result, Del Burgo did not regret Tomás Domínguez Arévalo resignation and welcomed the appointment of Manuel Fal Conde.
Requeté.
In 1931 del Burgo engaged in the Carlist militia Requeté, at that time undergoing rapid expansion and partial restructuring. He demonstrated enormous dedication and great organizational capacity, along Generoso Huarte becoming one of key field commanders and focusing on the province of Pamplona. Participating in street brawls against socialist groups, he was arrested following the clashes of April 1932. Charged with trafficking arms – which he did indeed – del Burgo was acquitted due to lack of evidence, though in total he remained behind bars for 6 months. Released, he again became one of the most active Requeté operatives in Navarre, especially under the new, strictly military organization engineered by Varela.
Early 1934 del Burgo led one of the two already formed Pamplona piquetes. During the spring he and 14 other Carlists travelled to Italy under the false Peruvian identities; at the air base they underwent specialist military training, focusing on usage of machine guns and grenades, infantry tactics and urban warfare. Back in Spain, del Burgo wrote tactical rulebook with instructions as to group alignment and positioning, fire drills, march and engagement distances etc., all calibrated for small groups and mostly urban combat. Promoted to lieutenant, he broadened his training to the Carlist NCOs. Early 1936 Pamplona could already present one battalion; del Burgo was leading one of its 3 companies, all commanded by Alejandro Utrilla Belbel.
Shortly before and during the first day of the coup del Burgo was instrumental to organizing the Pamplona Requeté units. The Pamplona tercio was fragmented, del Burgo's company incorporated into a mixed 7th Batallón del Regimiento de América. He left Pamplona on July 19; following few days in Rioja, the battalion was moved to Navafria area in Sierra de Guadarrama, in August engaged in heavy fighting for the Somosierra pass. In September he was withdrawn to a hospital in the rear. Recovered, del Burgo co-organized the Álavese battalion of Tercio de Nuestra Señora de Begoña and as its officer re-entered combat in Biscay. Reportedly shocked by destruction of Guernica, he engaged in a related brawl against an army officer and deployed a requeté platoon safeguarding the symbolic oak. In mid-June 1937 captain del Burgo was heavily wounded when storming the Bilbao Iron Ring. Evacuated, he has never returned to the frontline, serving as Delegado de Requetés del Seńorío de Vizcaya.
Between "falcondismo" and "carloctavismo".
During the unification crisis of early 1937 del Burgo sided with the intransigent falcondistas, considering amalgamation into FET a manipulation on part of the Navarrese. He labeled occasional enthusiasm for unification a "collective psychosis". To underline Traditionalist identity, he was commissioned to compile a concise doctrinal handbook, published in April 1937 as "Ideario Tradicionalista". Some scholars claim that the collaborationists intended to get rid of del Burgo, still active in national AET, and send him abroad, as a Traditionalist tutor of Don Juan. Late 1937 Fal considered del Burgo a man of trust and included him on the list of potential replacements for the disloyal members of Navarrese junta, sent to the provincial leader Baleztena. As the latter preferred to steer cautiously between and falcondistas and ignored the suggestion, it was only in 1939 that del Burgo entered the executive of Hermandad de los Caballeros Voluntarios de la Cruz, intended as semi-official Fal's outpost in Navarre. In 1940 Fal appointed him to represent Navarre in a vasco-navarrese junta, though de Burgo's opposition to unification was already burning out and giving way to sense of defeat, resignation and frustration.
Del Burgo's departure from the falcondista camp stemmed not from differences on policy towards Francoism, but was the result of dynastical disputes. Though in the mid-1930s he was fanatically loyal to the dynasty, following the death of Don Alfonso Carlos del Burgo only hesitantly accepted the regency of Don Javier; instead, he advanced the cause of Don Carlo Pio as early as on the frontline in 1937. When the latter officially raised his claim as Carlos VIII in 1943, del Burgo joined his followers - dubbed carloctavistas - and constructed a supporting dynastical interpretation. Unlike many Carlos VIII supporters he did not sympathize with the Axis and did not enter the first carloctavista executive of 1943. It was only in 1945 that del Burgo became one of the Comunión Católico-Monárquica leaders and vice-president of the claimant's Navarrese Royal Council. Don Carlos Pio was only 3 years del Burgo's senior and equally radical; the two have forged a close relationship and exchanged a lengthy correspondence over the years. In the late 1940s Del Burgo's worked to capture new supporters and in 1950 he managed to reconstruct Navarrese AET as a carloctavista organization. However, at that time he was replaced as a key claimant's man in the province by .
The unexpected 1953 death of Don Carlos Pio left the carloctavistas puzzled. While most of the group focused on Carlos VIII's older brother Don Antonio and minor factions backed either his sons or another brother Francisco Jose, del Burgo advocated allegiance to the oldest daughter of Carlos VIII, Alejandra. According to del Burgo, having been a minor she would appear as "abanderada provisional", until the claim is passed to her anticipated male descendant. This option received scarce support and no faction was built around it. Del Burgo was left without clear dynastical allegiances; over time he developed a critical view of Carlos VIII, considering him "sold out" to Falange. He is not listed among the carloctavistas forming the camp of subsequent carloctavista claimants, those reconciling with Don Javier, or those joining Don Juan. though in the 1960s it was noted that he "había mostrado inclinación hacia los javieristas"
Between "franquismo" and "carlismo".
Del Burgo's access to the carloctavista camp made him reconsider his stand versus Francoism, as Don Carlos Pio pursued a decisively collaborationist strategy. In 1942, during the proceeding fragmentation and bewilderment of Navarrese Carlism, he stood on the carloctavista ticket in local elections to the Pamplona council and was successful, serving as until 1944. By this token, in 1943 and 1944 he performed the prestigious sanfermines task of setting off . The council role did necessarily imply collaboration, but promotion to colonel, 1943 appointment as a provincial Falangist delegate for communication and transport and vice secretary of FET Educación Popular section clearly did, especially that in the mid-1940s he openly started to advocate a possibilist policy. As in 1949 the Falangist zealot Luis Valero Bermejo was appointed a new provincial civil governor del Burgo was his man of trust, though when himself offered the jobs of civil governor of Lerida and Lugo he declined, claiming that he would never accept a post beyond Navarre. In 1950 he assumed the role of a provincial ministerial delegate for tourism and information. When the carloctavista collaborationism crashed with the death of Don Carlos Pio, del Burgo was left disoriented.
In the mid-1950s it was the mainstream Carlism which in turn commenced a possibilist strategy, with intransigence abandoned and Fal replaced by Valiente. None of the sources consulted offers any information on a would-be rapprochement (or hostility) between del Burgo and the Javieristas, though his "Ideario" still served as their doctrinal point of reference. In 1958 he was appointed as representative of Navarre in the Falangist , a largely fictitious executive body which nevertheless automatically guaranteed membership in the Francoist quasi-parliament, Cortes Españolas; it is not clear what if any background mechanism elevated him to the position. Del Burgo served in Comisión de Leyes Fundamentales, though there is no information available on his stand versus the constitutional laws discussed. Though re-appointed in 1961, he did not have his ticket prolonged in 1964; according to some sources, he resigned due to differences with Francoism.
As a former radical aetista and an active collaborationist, he would have seemed a potential ally for the new generation of Carlist progressists, also revolutionary, socially-minded, AET members and apparently keen to exploit possibilist opportunities within Francoism. However, they preferred to jump on the older version of de Mella's sociedalismo and there is no trace of any link between del Burgo and the Huguistas. One source suggests that as Delegate of the Ministry of Information and Tourism he sabotaged their plans, preventing the presence of Carlos Hugo at the annual Montejurra gathering in 1964. Del Burgo is not mentioned as taking part in power struggle between Traditionalists and Progressists, which erupted within Carlism in the late 1960s, though he maintained at least private contacts with Traditionalists like Manuel Fal Conde in 1969.
Public servant.
Already in May 1936 del Burgo won the contest for the job of an auxiliar at Archivo de la Diputación Foral de Navarra. Following the Civil War pause, in 1939 he resumed the civil servant career; at that time the provincial Navarrese government decided to detach the existing Biblioteca de Navarra from Instituto de Segunda Enseñanza and establish it as a stand-alone ; del Burgo became the first head and organizer of the new unit. He remained at its helm for the next 43 years, presiding over its opening in 1941, removal from building to "La Agrícola" on Plaza de San Fernando in 1972 and re-formatting it from a scholarly institute to the Navarrese public library. On top of this job, in 1941 del Burgo became head of Red de Bibliotecas de Navarra, the provincial network of local libraries, in course of his service having opened 65 public libraries across the province. Until the late 20th century he remained active in professional archivist and librarian organizations.
In 1950 del Burgo became the provincial delegate of Ministry of Information and Tourism. At this position he acted as head of the Navarrese Francoist censorship office, banning a number of films, theatric performances, books and songs; he is particularly remembered for censoring the marketing campaign of "The Mark of Zorro" movie; the original advertising slogan, "El Zorro, friend of the poor, feared by tyrants" apparently sounded too hazardous for the regime. In 1964 del Burgo left the ministry and assumed the job of Director de Turismo, Bibliotecas y Cultura Popular de la Diputación Foral de Navarra. Having been responsible for mass culture, he edited and published around 400 popular brochures - writing some of them himself - and organized hundreds of cultural events, mostly highlighting traditionalist values at the expense of democratic ones. By some sources he is described as periodista. As head of tourism del Burgo promoted the province across Spain, developed the Navarrese section of El Camino de Santiago, drafted "Ordenación Turística" (1964) for the entire trail and wrote tourist guides related to Navarre. Since the late 1960s he was also director of Escuela Municipal de Artes aplicadas y Oficios artísticos. Resigned from all public posts in 1982, a month before his 70th birthday.
Historian.
As a historian del Burgo focused on – if not limited himself to – Carlism and Navarre, with a clear preference for the 19th and 20th centuries and for the history of foralism. His works range from syntheses to monographs, biographies and case studies. As an amateur with no systematic training, he did not adhere to any specific methodology, though he remained chiefly within the limits of political history and based his studies on thorough research in primary sources, mostly the printed ones.
Del Burgo's key historical work is the monumental "Bibliografía de las guerras carlistas" (1953-1966), the opus which spanned across 5 volumes, cost 25 years of work and indexed more that 10,000 works; until today it remains a point of reference for all students of the subject. Second to be listed is "Historia General de Navarra" (1978), a massive synthesis of the region's past, heavily based on his earlier works and the result of 10-year-research. Then come detailed studies related to the history of Carlism and Navarre, most prominent of them "Carlos VII y su tiempo" (1994) and "La sucesión de Carlos II" (1967). Del Burgo is also the author of "Conspiración y guerra civil" (1970), the work intended as a synthesis, though today it is – somewhat unintentionally – broadly used rather as a historical source. Finally, he authored a number of minor publications ranging from petty contributions to popular booklets, like "Vida y hechos militares del mariscal de campo Don Juan Manuel Sarasa narrados por él mismo". Many of his works form part of auxiliary sciences, bibliography or metabibliography, source criticism, or prosopography.
As a historian del Burgo is praised for sound referential basis; the critics usually point to his Carlist bias. He is particularly criticized for an attempt to recalculate the number of victims of the Rightist terror in Navarre; other historians support 4 times higher figures. This controversy coincides with the fact that del Burgo was personally accused of a war crime, the charge that left him very embittered and which he always denied; it is also disqualified by some historians. As an amateur he has never assumed academic duties, though he became member-correspondent of ; for his bibliographical work del Burgo received the National Literary Prize in 1967.
Writer.
Del Burgo commenced his literary career in the early 1930s, publishing short dramas revolving around episodes from the Carlist history and sometimes played at the local party circulos: "Lealtad" (1932), "Cruzados" (1934) and "Al borde de la traición" (1936). Calibrated as praises of old Carlist virtues and with clear moralizing objectives, they are classified as costumbrismo nostalgico. In 1937 he tried his hand as a poet with "En Pos. Ensayo poético". Following the Civil War break del Burgo switched to novels: "El valle perdido" (1942), "Huracán" (1943) and "Lo que buscamos" (1951). Set in the history of the Civil War, the first two were designed to acclaim patriotic merits and presented a traditional narrative style, though with plots accommodating magical threads; the third one assumed a different tone, infected with bitterness and naturalism. After the break of the 1960s and 1970s, dedicated mostly to historical research, del Burgo returned to drama with "Llamada sin respuesta" (1978), to poetry with "Soliloquios: en busca de un rayo de luz perdido" (1998) and to prose with "La Cruz del fuego" (2000), a well-documented adventurous intrigue from the times of Henry I of Navarre.
Though heavily contributing to Carlism in literature, Del Burgo has not made it to the history of Spanish belles-lettres of the 20th century, be it either general synthetic accounts or encyclopedias and dictionaries. He is missing even in detailed studies on the Francoist era novels. His prose is classified as falling into the "novela de la guerra civil española" category. Appreciated for documentary value, del Burgo's novels are described as production of scarce esthetic and literary value, very repetitive in terms of its structures, primitive in terms of narration and Manichaean in terms of personalities. Present-day scholars point to two interesting features of his novels. One is a strong Basque ethnic sentiment, calibrated in pre-nationalist, sabinan terms of an ancient Basque Eden. Another is equally idyllic rustic thread, advancing a fairly typical Carlist praise of ruralismo and mistrust towards urban life.
Del Burgo's novelist work was acknowledged by Premio de Literatura y Periodismo de la Secretaria General de FET (1954). Apart from the national prize of 1967, he was also rewarded by the Bayonne-Pamplona International Competition Award (1963), Fundacion de Larramendi Award (1993) and Badge of the Order of Alfonso X the Wise (1997), conceded by the Ministry of Education and received in Pamplona in May 1999 from the then Minister of Education and Culture, Mariano Rajoy. Permanent Councilor of Institución Príncipe de Viana, himself he has never received the , set up in 1990 and awarded by the .


Choice of law

Choice of law is a procedural stage in the litigation of a case involving the conflict of laws when it is necessary to reconcile the differences between the laws of different legal jurisdictions, such as sovereign states, federated states (as in the US), or provinces. The outcome of this process is potentially to require the courts of one jurisdiction to apply the law of a different jurisdiction in lawsuits arising from, say, family law, tort, or contract. The law which is applied is sometimes referred to as the "proper law." Dépeçage is an issue within choice of law.
Choice-of-law stage.
The "traditional approach" looks to territorial factors, e.g. the domicile or nationality of the parties, where the components comprising each cause of action occurred, where any relevant assets, whether movable or immovable, are located, etc., and chooses the law or laws that have the greatest connection to the cause(s) of action. Even though this is a very flexible system, there has been some reluctance to apply it and various "escape devices" have developed, which allow courts to apply their local laws (the "lex fori") even though the disputed events took place in a different jurisdiction. The parties themselves may plead the case either to avoid invoking a foreign law or agree to the choice of law, assuming that the judge will not of his or her own motion go behind the pleadings. Their motive will be pragmatic. Full-scale conflict cases take longer and cost more to litigate. However, the courts in some states are predisposed to prefer the "lex fori" wherever possible. This may reflect the belief that the interests of justice will be better served if the judges apply the law with which they are most familiar, or it may reflect a more general parochialism in systems not accustomed to considering extraterritorial principles of law. One of the most common judicial strategies is to skew the characterization process. By determining that a claim is one involving a contract instead of tort, or a question of family law instead of a testamentary issue, the Court can change the choice of law rules. For example, if an employee is hired by an employer in State A, is injured due to the employer's negligence in State B, and files a lawsuit to recover for the injury in State A, the court in State A might look to the employment contract to see if it contained a clause that governed the employer's duty of care with respect to the employee. If so, the court may be able characterize the claim as a breach of the contract, instead of a tort, and apply the law of the State A either because it was the place where the contract was made (the "lex loci contractus") or, if it were the place where the wage or salary was to be paid, where the contract was intended to be performed (the "lex loci solutionis").
In this context, since the 1960s, the courts in the United States began developing a number of new approaches, as well as new escape devices. This reflects the number of different laws that might be relevant in any given case before an American court. There is significant interstate trade and social mobility, and with the laws of each state of the Union representing a possible opportunity for conflict, it was necessary to produce a coherent system that could be applied in the courts of all fifty states.
Renvoi.
To limit the damage that would result from forum shopping, it is desirable that the same law is applied to achieve the same result no matter where the case is litigated. The system of renvoi, which literally means "send back", is an attempt to achieve that end.
Traditional approach.
The traditional approach is based on the idea that the territorial sovereignty of states must be respected. For example, when an event happens in a state that gives rise to a lawsuit - if two parties are involved in an automobile accident, for example - that state in which the accident occurred provides the parties with certain "vested rights". These rights include such things as the ability of a plaintiff to file a lawsuit, the imposition of a statute of limitations to prevent a defendant from being subjected to a lawsuit after too much time has passed, limitations on recovery, and specified burdens of evidence. These so-called "vested rights" compete with the policy claims of other states for their laws to be applied. What follows is a generalised summary of the rules. The approach in the U.S. is rather different (see Conflict of laws in the United States).
Status.
Status is relevant for a wide array of issues. Self-evidently, unless the proposed litigant has legal personality, there will be no jurisdiction. It will also be relevant to immigration, entitlement to social security and similar benefits, family law, contract, etc. The choice of law rule, the law of the domicile ("lex domicilii") if the forum is common law or law of nationality ("lex patriae") or habitual residence if the forum is civil law, applies to determine all question of status and its legal attributes. The "lex fori" determines the domicile, nationality or habitual residence, and applies that law to establish an in rem set of rights and capacities. Thus, under some laws, the status of illegitimate affects the rights of inheritance in the case of an intestacy, etc. As to corporations, the choice of law rule is the law of incorporation (the "lex incorporationis") for all matters of capacity, validity, shareholders' rights, etc.
Contracts.
The choice of law rules for contracts are more complicated than the law affecting other obligations because they depend on the express or implied intentions of the parties and their personal circumstances. For example, questions as to whether a contract is valid may depend on the capacity of the parties to enter into a contract. This could be decided by reference to the "lex domicilii", "lex patriae" or habitual residence of the parties, or for policy reasons, by reference to the "lex loci contractus" (where the contract was made). But, if the contract was made electronically, where the contract was actually made must first be decided either by the "lex fori" or the putative proper law depending on the forum rules. There may also be problems if the parties selected the place where the contract was made in the hope of evading the operation of some mandatory provisions in another relevant law.
On the other hand, deciding matters relating to "performance" will usually depend on the "lex loci solutionis". Another unique characteristic of contracts is that the parties can decide which law should apply for most purposes, and memorialize that decision into the contract itself (see forum selection clause and choice of law clause)although not every jurisdiction will enforce such provisions. For the harmonising provisions on contractual obligations in EU law, see the Rome Convention (contract).
The Rome I Regulation constrains the choice of law for special types of contracts. With a view to the weaker parties, such as consumers, employees and insurants, special choice of law rules are laid down by articles 5-8. The most important rules for companies, mostly closing contracts with consumers, are listed in Art. 6. Art. 6 (I) defines the consumer contract as a contract where the consumer acts as a private person whereas the businessman acts for his commercial purpose. This articles also says that in absence of an explicit choice of law, a protected consumer contract is governed by the law of the consumer's habitual residence. In Art. 6 (II) the involved parties are given the possibility of a free choice of law. But the choice of law is legally void, if the consumer protection is limited by this choice.
Tort.
The presumptive rule for tort is that the "proper law" applies. This is the law that has the greatest relevance to the issues involved. In public policy terms, this is likely to be the law of the place where the key elements of the "wrong" were performed or occurred (the "lex loci delicti commissi"). As established in the case of [1969], both plaintiff and defendants were British Soldiers Residents Stationed in Malta. Having an accident in Malta the court looked at the Lex Loci relating to its dual action-ability.
Family law.
As to marriage, both formal and common law, the general rule is the "lex loci celebrationis" determines its validity, i.e. the law of the place where the marriage is celebrated, unless the purpose of the marriage offends a public policy of the domicile/nationality/habitual residence state. Hence, some states limit the capacity of their citizens to celebrate a monogamous marriage to a person of the opposite biological sex, or prohibit marriage between degrees of consanguinity, etc. Questions of nullity and divorce straddle Family Law and status because the outcome of the judicial proceedings affects status and capacities, and also overlap with the more general question of when the courts of one state will recognize and enforce the judgments of another state.
Property.
The rule for immovable property (called real property in common law states) is that the "lex situs" applies to all questions of title. Movable property (called personal property in common law states) claims are governed by the law of the state in which the property is located at the time the rights are supposedly created. An important distinction, however, must be made for a contract which has some incidental effect on property, both immovable and movable, such as a loan with property pledged as a collateral. If the property is incidental to the contract, then the contract is evaluated under traditional choice of law principles for a contract. If, however, the primary purpose of the contract is to transfer the property, then the entire contract will be evaluated under the law of the state where the property is located.
Trusts and succession.
Where an inter vivos or testamentary trust includes immovables, reference must be made to the "lex situs" on all aspects relating to title and land use. Similarly, title to movables including choses in action, should be determined by "lex situs", i.e. the law of place where each item is located at the time the trust is created. Once created, all questions of administration are governed by the law specified in the trust instrument. In the unlikely event that the instrument is silent, the trust would be governed by the proper law.
All questions of prenuptial trusts and transfers are determined by the law of the transferor's domicile, nationality or habitual residence at the time of the marriage.
All questions relating to wills (and, as an incidental question, any testamentary trusts which the will purports to create), are governed by the law of domicile, nationality or habitual residence at the time of death. Questions of title affecting immovables are determined under the "lex situs".
Illustration: Mr. "Z" died in US leaving immovable properties in US and other immovable properties in Kilimanjaro Tanzania. "lex situs" the law applicable would be of the place where the immovable is located. that is to say those in US to be administered according to the US laws and those in Tanzania according to the laws of Tanzania.(2013)


Free School Under the Bridge

The Free School Under the Bridge is a private school in Delhi, India. It provides free-of-cost tuition to underprivileged children. Almost all the students come from the slums situated adjacent to the Yamuna river and are enrolled in nearby government-run schools. Started in 2006 by grocery shop owner Rajesh Kumar Sharma with just two children, the school now has a strength of more than 300 students. Seven teachers volunteering in their free time help these students to better understand their school curriculum. The school is run in two shifts with a morning shift for boys and an afternoon shift for girls. It has no permanent building and its makeshift campus is situated under a Delhi Metro bridge with pillars serving as its boundary marker and blackboards painted on a wall of Yamuna Bank Metro Depot. It receives no help from either the government or any non-governmental organisation.
History.
The school was founded in 2006 by Rajesh Kumar Sharma, a grocery shop owner, for underprivileged children. Originally from the Hathras district of Uttar Pradesh, Sharma could not complete his Bachelor of Science due to financial reasons. The idea to start a school for children from poor families struck him while he was wandering near the Yamuna River and saw children playing in dust and mud near an under-construction metro bridge. He asked the parents why their children were not attending school, and they expressed their helplessness at being unable to afford their children's education and how there was no school in the neighbourhood. Sharma began the school by teaching two children. He believes that "no one should be deprived of education due to poverty and to fulfil his or her dream" and devotes more than 50 hours in a week to teaching in the school.
Programme.
The school provides free tuition to children already enrolled in nearby public schools, helping them better understand their school curriculum. It tutors students in learning subjects like mathematics, English, Hindi, science, history and geography. Students are encouraged to get enrolled in nearby government-run schools as it provides them opportunity to avail benefits like mid-day meals and free textbooks, among others. Many parents express their reluctance to send their children for tuition, as they need them to either work part-time jobs to support their families, or to take care of their younger siblings at home. Only after extensive persuasion do such parents allow their children to attend the school. Almost all the students come from the slums situated close to the Yamuna river.
The school is operated in two separate shifts: the morning batch from 9 a.m. to 11a.m. is for boys and the afternoon batch from 2 p.m. to 4:30p.m. is for girls. More than 300 students of the age group four to fourteen attend the school. Seven teachers besides Sharma volunteer to teach in their free time. Students bring their own textbooks and they are taught in groups.
Campus.
The school is situated under a Delhi Metro bridge close to Yamuna Bank metro station in East Delhi. It is a makeshift structure with a metro bridge functioning as overhead roof and bridge pillars serving its boundaries. Five blackboards have been painted on a wall of Yamuna Bank Metro Depot. There are separate toilets for boys and girls in the proximity of school. There are no benches and students sit on scraps of carpet or just the dirt. It receives no help or funding from either the government or any non-governmental organisation (NGO). A few NGOs approached Sharma to associate with the school but he rejected their help because of their lack of commitment towards the goal of the school and their questionable interests. Only non-financial contributions such as packaged food, water bottles, chairs and carpets among others are accepted.


Bagrat Khutaba

Bagrat Khutaba (Russian: Баграт Хутаба; born 10 February 1982) is the Ambassador Extraordinary and Plenipotentiary of the Republic of Abkhazia to the Syrian Arab Republic and a retired freestyle wrestler and the current Chairman of the State Committee for Physical Culture and Sports of Abkhazia. Khutaba was appointed on 11 April 2015 by President Raul Khajimba — up until that point, Sports had been part of the Ministry for Education.
Bagrat is the son of Rashid Khutaba, a heavyweight freestyle wrestler who won the European title in 1982. Coached by his father, Bagrat won a bronze medal at the 2001 Junior World Championships. At the time he studied and trained in Moscow and competed for Russia. His younger brother Badzhgur is also an international heavyweight freestyle wrestler.
References.
the Ambassador Extraordinary and Plenipotentiary of the Republic of Abkhazia to the Syrian Arab Republic on July 21,2020
https://syrianobserver.com/EN/news/59496/president-assad-receives-credentials-of-algerian-and-abkhazian-ambassadors.html
http://mfaapsny.org/en/allnews/news/othernews/bagrat-khutaba-vruchil-veritelnuyu-gramotu-validu-al-muallem/


Halifax Centre

Halifax Centre was a provincial electoral district in Nova Scotia, Canada, that elected one member of the Nova Scotia House of Assembly. It existed from 1933 to 1967


South African Special Forces Supply Unit

The Special Forces Supply Unit's role is to oversee and maintain all logistical, technical and other equipment for Special Forces. This includes all equipment and material unique to Special Forces.
History.
In order to be able to maintain and store the parachute equipment according to regulations, the Special Forces Supply Depot also has a modern parachute packing, store and maintenance facility.
In 1991, during the rationalisation and re-organisation within the Defence Force, the Special Forces Supply Depot was renamed 1 Maintenance Unit.
When Special Forces Headquarters moved temporarily from Speskop to Defence Headquarters in 1992, 1 Maintenance Unit was relocated to Wallmanstal, north of Pretoria.


Hannes Germann

Hannes Germann (born 1 July 1956) is a Swiss politician and current member of the Swiss Council of States for the Canton of Schaffhausen. Elected to the council in 2002, he is a member of the Swiss People's Party (SVP/UDC).


Tamaz Gogia

Tamaz Gogia is the current Chairman of the Central Election Commission of Abkhazia.
Early life.
Gogia was born on 5 July 1961 in Tkvarcheli and graduated from the Krasnoyarsk Technical University.
Career.
From October 1993 until December 1998, Gogia served as Deputy Head of Ochamchira District.
In March 1998, he was appointed as the first Chairman of the newly created State Committee for State Property Management and Privatisation by President Vladislav Ardzinba. Gogia served in this post under Prime Ministers Sergei Bagapsh, Viacheslav Tsugba and Anri Jergenia, but was not in re-appointed in December 2002 in the cabinet of Gennadi Gagulia.
On 16 June 2003, President Ardzinba appointed Gogia as Administration Head of Gulripshi District. In the beginning of 2004, district officials stayed away from work in protest of what they perceived as rudeness from Gogia. In response, Gogia applied for resignation which President Ardzinba granted on 9 February, appointing First Deputy Head Aslan Baratelia in his stead.
Gogia became a member of the Central Election Commission in 2004, but resigned during the Mandarin Revolution following on the October 2004 Presidential election.
In 2016, Gogia was once more appointed to the Central Election Commission. On 23 December, he was elected chairman during the first meeting of the CEC in its new composition (outgoing chairman Batal Tabagua had not been re-appointed to the CEC).


Charlottetown-West Royalty

Charlottetown-West Royalty is a provincial electoral district for the Legislative Assembly of Prince Edward Island, Canada. It was created prior to the 2019 election from parts of the former districts Charlottetown-Lewis Point and West Royalty-Springvale.
The riding is located in the city of Charlottetown, including the neighbourhoods of Lewis Point and West Royalty.
Referendum and plebiscite results.
2019 electoral reform referendum.
The 2019 Prince Edward Island electoral reform referendum was held on April 23, 2019.


Pro Swing Inc v Elta Golf Inc

Pro Swing Inc v Elta Golf Inc 2006 SCC 52 is a leading Canadian case decided by the Supreme Court of Canada on conflict of laws. The Court held that foreign non-monetary judgments may be enforced in Canada where they have been rendered by a court of competent jurisdiction, the rendering is final, and the nature of the judgment is such that comity requires it to be enforced.
Background.
Pro Swing is an American company that sells golf equipment under the "trident" trade-mark. Elta Golf is an Ontario company that sells golf equipment that includes products with a trade-mark similar to that of the "trident".
Pro Swing sued for trade-mark infringement in Ohio. A settlement was reached which ordered Elta Golf to refrain from selling any products with the trident logo.
In 2002, Pro Swing filed to an Ohio court for contempt of court for Elta's breach of the settlement. The court granted the order. Pro Swing then filed in the Ontario Superior Court of Justice for enforcement of the order.
The motions judge found that the non-monetary order was valid, but found certain parts duplicative and had them severed from the order.
On appeal to the Court of Appeal for Ontario, the court found the order was unenforceable due to ambiguity in the order regarding its scope of application.
Opinion of the Court.
Justice Deschamps wrote the majority opinion. She ordered the appeal dismissed.
The old rule for foreign judgments required that they be final, conclusive, and for a monetary amount. Deschamps found this rule to be outdated and stated that a new rule for non-monetary orders based on comity was needed.
She proposed that non-monetary judgments should be enforced when
On the current facts she found the order unenforceable. The contempt order is quasi-criminal which should never be enforced. This public law element eclipses any other private law element. She further advised in "obiter" that courts should ensure there will be no conflict once the order is rendered, and should not allow punishments that are not available under the foreign jurisdiction.
Dissent.
McLachlin, in dissent, argued that incremental change was a preferable approach. The standard should be based on comity, order, and fairness.
When assessing an application, the court should not look at the judgment's merits. The only restrictions upon enforcement of foreign non-monetary judgments should be: