Ruddy turnstone migratory bird, breeding in northern parts of Eurasia and North America and flying south to winter on coastlines almost worldwide. It is the only species of turnstone in much of its range and is often known simply as turnstone. It is a fairly small and stocky bird, long with a wingspan of and a weight of . The dark, wedge-shaped bill is long and slightly upturned. The legs are fairly short at and are bright orange. In all seasons, the plumage is dominated by a harlequin-like pattern of black and white. Breeding birds have reddish-brown upper parts with black markings.
Creature of statute them may not term them as creatures of statute. Australia also uses the term "creature of statute" to describe some governmental bodies. The importance of a corporate body, regardless of its exact function, when such a body is a creature of statute is that its active functions can only be within the scope detailed by the statute which created that corporation. Thereby, the creature of statute is the tangible manifestation of the functions or work described by a given statute. The jurisdiction of a body that is a creature of statute is also therefore limited to the functional scope written