Effects of Flying on Cavities

Effects of Flying on Cavities Aviation dentistry – New Horizon, New Challenge Abstract: After the innovations in aviation at the beginning of the 20th century, many in -flight pathologic and physiologic conditions were reported. Changing atmospheric pressure, especially if it is rapid, can cause discomfort and damage to the oral cavities and maxillofacial areas unless the pressure within these cavities containing gas is able to equilibrate with the external air pressure. Out of these conditions- barodontalgia (pain due to gas entrapment) and barotrauma (pressure induced tooth fracture, restoration and tooth fracture) was most frequently seen to occur. Due to partial pressurisation of aeroplanes cabins and improvement in dental techniques and oral health awareness, prevalence of flight-related oral manifestations has declined. It is important for the dental practioners to be familiar with these facts and not to neglect dental education with respect to aviation. Aircrew patients as well as air passengers often make it challenging for the dentist to treat several flight-re lated conditions. Correct diagnosis should be made before these conditions lead to serious complications. With thorough practice and experience, the aircrew are now able to avoid, or treat, these pressure related problems. Keywords:Â  Barodontalgia, Barotrauma, Aviation Dentistry. INTRODUCTION It is a known fact that at higher altitudes there is a reduction in air density and air pressure.The decrease in pressure is that at 18,000ft, air pressure is half that of that at sea level and at 33,000 ft. it is quarter as seen at sea level.1 This reduction in air pressure has a many negative effects on aviators. When an aircraft is at a high altitude, atmospheric pressure will be too low but inside aircraft pressure is maintained such that it is comfortable for crew and passengers. The pressure and temperature regulation in aircraft is done by means of aircycle machines and outflow valves.2 During flight, the aircrew is responsible for the lives of the aircrew members and passengers for completing the flight successfully. Any problem within the flight could lead to failures in the flight’s safety. 3 Dental practice and education is evolving with technological advancements. The focus is now on prevention. With the advanced expansion in the airlines industry with air travel now being the chief mode of transport, special attention must be paid towards the crew members and air travellers.4 Aviation dentistry primarily deals with the oral and dental health status of the aviators. It deals with the diagnosis, principles of prevention and treatment, disorders or conditions which are related to the oral cavity and maxillofacial area and their impact on those who travel in such an environment where there is change in pressure than that of the normal atmospheric pressure.5 Several areas of the body normally contain gas which includes the lungs and air-passages, the sinuses of the face, the stomach and bowel, and the middle ear cavity. Gas may be present in other areas of the body under abnormal circumstances such as the gas produced when a tooth abscess forms, or sometimes under a tooth’s filling. 2 A person in flight is subjected to reduced air pressure.Here, the gas present within the body will expand. This is not a problem if the gas communicates freely with the outside (as with the mouth, nose, and to a degree the sinuses and the middle ear cavity). The gas merely expands and escapes to the outside atmosphere. But if the gas doesn’t communicate freely with the outside, its expansion will cause a build-up in pressure on the cavity walls causing discomfort .It can even impair the function of the organ involved .6 Large changes in altitude can cause toothache (Barodontalgia = pressure-tooth-pain). The reason this occurs is either the presence of small pockets of gas in deep (usually unlined) fillings, or collections of gas in areas of decay, gum inflammation, or root abscesses where the pain can be quite severe.7 Due to infrequent meals, the aircrew members may suffer some gastro- intestinal problems too.8 With practice and experience aircrew are able to avoid, or treat, these pressure related problems .5 We as dentists should prevent the creation of in-flight hazards when we treat aircrew members and frequent flyers. BAROTRAUMA Barotrauma refers to injury sustained from failure to equalize the pressure of an air-containing space with that of the surrounding environment. The most common examples of barotrauma occur in air travel, scuba diving , hyperbaric oxygen therapy or exposure to shock waves from an explosion .9 It is a tissue injury seen due to changes in pressure, wherein the gas compresses or expands which is present in various hard or soft body structures. In cases where there is increased pressure outside the body, this pressure is equally transmitted throughout the blood and body tissues, which do not compress because they are composed mainly of liquid. However, gases (such as the air inside the lungs, sinuses, or middle ears) compress or expand as outside pressure increases or decreases causing pain, numbness and damage to the involved tissue. 5,10 Barotrauma of non-dental origin Barotrauma can commonly affect the ears which is also called aero-otitis or Barotitis .11 It is observed that plane landing leads to extreme pain in the ear (the pressure change can create a vacuum in the middle ear that pulls the eardrum inward causing pain), dizziness (vertigo), bleeding or fluid coming from the ear (due to a ruptured eardrum) and ultimately hearing loss.12, 13 Risk of barotrauma is increased by conditions that prevent air from freely flowing between spaces, such as sinus congestion or blockage of Eustachian tube or any other upper respiratory tract infection.14 It may impair the balancing function of the Eustachian tube, thus predisposing the individual to barotrauma. However, pulmonary barotrauma is the most serious amongst the other types of barotrauma. Pulmonary barotrauma may cause shortness of breath, chest pain, and feeling of fullness in the chest, pain that radiates to the neck and/or shoulders, light-headedness, seizure or coma. Potential complications can include pneumothorax and stroke. Measures that can help prevent pulmonary barotrauma include ascending slowly and breathing during ascent .15 High altitudes can also cause acute or chronic inflammation of one or more of the paranasal sinuses, mainly the frontal sinus . This is produced by the development of a pressure difference (usually negative) between the air in the sinus cavity and that of the surrounding atmosphere .This condition is termed as Barosinusitis, Sinus barotrauma, Aerosinusitis or Sinus squeeze .14 Normally, there is no air pressure differential between the sinuses and the outside environment. Barosinusitis can occur and be manifested as toothache (indirect barodontalgia)16. Vacuum created inside the sinus may also seem to cause damage to the ethmoid cell mucosa which may trigger the ethmoid nerves (branches of the ophthalmic branch of the trigeminal nerve that innervate the mucosa on the inner surface of the sinus).This may lead to orbital and/or peri-orbital headache. 17 To prevent the above risks from occurring, it’s better to postpone the flight for people suffering from a cold or congestion . Using a decongestant could help in some cases. To relieve the pressure during take-off and landing sucking candy, chewing gum, yawning or breathing with the mouth open can be beneficial .Usage of filtered earplugs can help to slowly equalize the air pressure against the eardrum. Since one does not swallow enough during sleep, keeping awake during descent can also prove helpful. Barotrauma of dental origin BARODONTALGIA Barodontalgia is an oral (dental or nondental) pain caused by a change in barometric pressure in an otherwise asymptomatic organ. Gases are confined within the closed spaces due to which it is unable to contract to adjust the internal pressure. Individuals experience pain which may be sharp or squeezing in nature. Whether the pain occurs during ascent or descent depends entirely on the related pathology. 5 Generally, pain on ascent is related to vital pulp disease (i.e., pulpitis) and pain on descent to pulp necrosis or facial barotrauma .Pain related to periapical disease can appear during ascent as well as descent.9 The pain usually ceases when returning to onset level or ground atmospheric level but can last longer if caused by periapical disease or facial barotrauma. Barodontalgia is a symptom rather than a pathologic condition itself. In most cases, it is an exacerbation of pre-existing subclinical oral disease.18 Several suggestions to explain the pathogenesis of barodontalgia were given. Strohaver 19 in 1972 advocated the differentiation of into direct and indirect types. In direct barodontalgia, reduced atmospheric pressure leads to direct effect on the affected tooth, whereas in the indirect type, dental pain is due to the stimulation of the superior alveolar nerves at the time of maxillary barosinusitis. Direct barodontalgia is characterised by moderate to severe pain, which usually develops during take-off. It is well localized and the patient can identify the involved tooth whereas indirect barodontalgia is a dull, poorly defined pain that generally involves the posterior maxillary teeth and develops during landing. Exposure to altered atmospheric pressure is obviously a significant factor resulting in pain production in barodontalgia with disease of the pulp as one of the probable cause. Ferjentsik et al 20 stated that normal pulp tissue would not produce pressure associated pain, regardless of whether restorations or caries were present. However, Hodges 21 has reported that dental pain could be produced in apparently healthy teeth when the atmospheric pressure was increased. Experimental research indicates that barodontalgia may depend on an increased pulpal pressure induced by pressure variations in the permeability of the dentinal tubules. Kollmann W (1933) said that barodontalgia could be due to expansion of trapped air bubbles under a restoration or against dentin that activates the pain receptors. 22 It could also be due to stimulation of nerve endings in an inflamed pulp or stimulation of nociceptors in the maxillary sinus with referred pain to the teeth. BAROMETRIC TOOTH EXPLOSION It was reported that teeth with pre-existing leaked restoration or remaining/recurrent caries lesions underneath restoration led to tooth explosion when exposed to changes in atmospheric pressure.23 This condition is known as Barometric tooth explosion, Barodontocrexis or Odontocrexis. Although the destructive potential of arrested or remaining carious lesions in daily life is minimal, it seems that these lesions may not be as asymptomatic or minimal in a pressure-changed environment. Calder and Ramsey 24 reported that all the damaged teeth either had poor quality of amalgam restorations with unfavourable clearance between the tooth and the amalgam or secondary caries under the restoration. Odontocrexis can potentially lead to severe pain, swallowing of the tooth fragments or even their aspiration. 25 Patients should be advised not to fly while having provisional restorations or temporary cement in their mouth. Leaky or faulty restorations should be diagnosed and replaced. Carious lesions should also be excavated and restored. Placement of cuspal coverage crowns could also be a preventive measure. PROSTHETIC CONSIDERATIONS Lyons et al. studied the retention of crowns to extracted teeth in environmental pressure changing conditions. The crowns cemented with glass-ionomer cement or zinc phosphate cement had reduced retention with the tooth. Crowns cemented with resin cement did not have reduced retention.26 This can be due to porosities incorporated at the time of manipulation of zinc phosphate cement and glass-ionomer cement. These microporosities expand and contract upon pressure changes leading to a weakened cement . 25 Microleakage was also detected in zinc phosphate and glass-ionomer cements after pressure changes , whereas no microleakage was detected in resin cement.27 Reduced barometric pressure can reduce the retention of full removable dentures (especially maxillary dentures) 28 Retention by osteointegrated dental implants is the best solution for edentulous fliers.4 RESTORATIVE DENTISTRY Pure oxygen inhalation may cause corrosion of dental amalgam restorations in cases due to increased percentage of oxygen.29 Differential thermal contraction in cases of low temperature of a high altitude environment is seen of amalgam materials as compared with tooth hard tissue. Harvey30 reported that cold temperature is unlikely the dominant mechanism underlying dental fracture. Excessive occlusal forces was also a factor in dental restoration dislodgement .Sognnaes, suggested that clenching or grinding of teeth was a causative factor for restorative failure.18 ENDODONTIC CONSIDERATIONS Although not evidence based, Rossi 31 contraindicated direct pulp capping in aircrew patients and recommended endodontic treatment in each case of suspected invasion to the pulp chamber in order to prevent sub-acute pulpitis or silent pulp necrosis and their potential barometric pressure-related consequences. Open unfilled root canals may cause leakage of the intracanal infected content to the periradicular tissues and subcutaneous emphysema . PERIODONTAL CONSIDERATIONS Decrease in salivation and dryness of mouth are few of the risk factors responsible for the development of caries lesions. Dryness of the mouth can be due to breathing of dry compressed gases in the aircraft. 32There is increased risk of periodontal diseases because of xerostomia. ORAL SURGERY When maxillary teeth are extracted, the dental surgeons should always rule out the existence of an oroantral communication as it can lead to sinusitis when exposed to a pressure changing environment .33 PREVENTION Caries excavations and restorations should be completed before airtravel. Leaky restorations should be replaced. During the restoration of a carious tooth, a thorough examination of the floor of the cavity should be done to rule out any penetration leading to the pulp chamber. In such cases a protective cavity liner should be applied (e.g. glass-ionomer cement) . During multi-visit endodontic treatment, the temporary restoration must be placed properly .When oroantral communication is diagnosed; referral to an oral surgeon for its closure is indicated.9 Cuspal coverage crowns could also be a preventive measure.Resin cements are preferred for cementation,as they give better retention. During flight, chewing gum or candy will increase salivation and prevent dryness in mouth. CONCLUSION There has been a tremendous increase in air travellers viz pilots, aircrew personnel, air passengers, flight attendants and leisure pilots. Special precautions must be taken during endodontic, restorative, prosthodontic and oral maxillo facial surgical treatments for the aircrew patients to prevent any kind of in -flight incapabilities leading to serious issues. Aviation dentistry is an emerging science which has been much neglected .With air travel gaining popularity, the in-flight dental hazards cannot be ignored anymore. The dental clinicians should take an initiative to raise awareness levels and sensitize the air travellers about this issue. The need of the hour is to promote diagnostic tools and treatment guidelines to the aviation industry to ensure wellness of air travellers.

Development of the Resulting Trust Essay

A resulting trust is defined and described as â€Å"a situation in which a transferee is required by equity to hold property on trust for the transferor; or for the person who provided the purchase money for the transfer† (Martin 1993, p. 233). Thus, a resulting trust arises when a person holds a property for another notwithstanding the fact that the former has the legal title in his name but holds the property as fiduciary for the benefit of the original title owner of the one who gave value therefore. Robert Chambers (1997, p. 9) classifies the situations under which a resulting trust may arise as, i. e. â€Å"apparent gifts, trusts which fail and quistclose trust† which shall be discussed at length in the next section. Apparent gifts refer to properties which are transferred gratuitously in favor of another or consideration for its transfer and there is failure on the part of the recipient to prove that said property is given as a gift. Such failure creates a presumption that the recipient holds it in trust for the transferor (Chambers 1997, p. b11). This presumption, however does not apply in cases where properties are provided by the father to his children or husbands in favor of their wives. In this case, the presumption of advancement will have to apply, thus the recipient shall have the right to enjoy the property unless it is proven by evidence that the property was not given or transferred as a gift (Chambers 1997, p. 11). ‘Trusts which fail ‘refer to express trusts that have failed. This category is further classified depending on whether the transfer was made on trust, into 1) presumed and 2) automatic (Chambers 1997, p. 40). It is considered as automatic when the transfer is made on trust but some or all the beneficial interest has not yet been disposed of and presumed when it is not made on trust. There is a presumption of advancement that is created for one to hold the property in trust including the beneficial interest in favor of the other (Chambers 1997, p. 40). The third classification is quistclose trust. This term originated from the case Barclays Bank Ltd. v. Quistclose Investments Ltd. The case involved money that was loaned for a specified purpose was held in trust for the benefit of the lender when it became impossible to fulfill the obligation [Barclays Bank Ltd. v. Quistclose Investments Ltd. , (1970) A. C. 567]. Discussion As previously discussed, gifts which were not proven as such are considered apparent gifts which gives rise to application of the presumptions of resulting trust or advancement. Both of these presumptions are â€Å"presumptions of facts, that fact being the intention of the person who has provided property to another† (Chambers 1997, p. 11). In explaining the presumptions, Lord Diplock in the case of Pettitt v. Pettitt, clarified that the presumptions are the court’s manner of imputing intent when it is relevant and important as it affects legal outcome and there is no evidence from which to infer intent [Pettitt v. Pettitt (1969) UKHL 5]. These presumptions are but a â€Å"consensus of judicial opinion† and are susceptible to change. The rule is that based on primary set of facts, the presumptions will apply and from the set of secondary facts, court can now presume the intent of parties (Chambers 1997, p. 11). In the Pettitt case, the legal title to the home belongs to the wife alone. Lord Upjohn stressed that any conveyance of a property when placed under the name of one spouse is considered also conveying beneficial title over it to the named spouse [Pettitt v. Pettitt (1969) UKHL 5]. Any improvements made by the husband did not give rise to interest in the absence of any agreement. He dismissed the application of the doctrine of resulting trust by applying the principles in the case of Dyer v. Dyer (citing 2 Cox 92 set out in full in White and Tudor’s Leading Cases in Equity 9th edition Vol. II page 749) where the doctrine was rebutted by the fact that the nominee was a child. There is a presumption of advancement which means that it is presumed to have been given as a gift because of the parties’ relationship. The presumptions can only come into play in the absence of evidence from which intentions of the parties can be inferred from and absence of consideration. He argues that similarly, this rebuttal must apply in the case of a wife [Pettitt v. Pettitt (1969) UKHL 5]. Barry and Cassell (1999, p. 1) summarized the possible situations relative to family home into 1) â€Å"where property is paid for by two or more people, but is conveyed into the name of one of them—in this case there is a presumption which is created to the effect that the registered owner holds the property in trust for those contributed by paying the purchase price or mortgage payments of the property. Thus, a resulting trust arises. As enunciated in a landmark case of Lloyds Bank Ltd v Rosset (1991) a claim of interest would mean payments that should have been made are for the part of the purchase price or mortgage payment. Any other contribution is not deemed by law as a claim to interest except in cases of divorce or separation, where substantial contributions have been made pursuant to section 37 Matrimonial Proceedings and Property Act 1970 [Lloyds Bank Ltd v Rosset (1991), 1 AC 107]. The second situation would be when an owner of a property transfers said property to another. The latter therefore is presumed to hold it in trust for the former. This, however is a refutable presumption and may admit of proof of to the contrary (Barry and Cassell 1999, p. 1). The second type of resulting trust is an express trust which failed. The categories of this type were distinguished in the case of Re Vandervell’s Trusts by Megarry, J. as presumed and automatic (Chambers 1997, p. 40). Presumed resulting trust refer to a situation where a property is transferred by A to B. However, the transfer was not made on trust. In this case, there arises a presumption, considering the failure for a provision, the absence of consideration and any presumption of advancement, which B holds on resulting trust in favor of A (Todd 1998, p. 1). On the other hand, automatic resulting trust refer to â€Å"transfer to B is made on trusts which leave some or all of the beneficial interest undisposed of† (Todd 1998, p. 1). The automatic trust is automatically created by the failure to dispose the beneficial interest, in whole or in part to A. This does not require presumptions or intent. Another classification was devised in the case of Westdeutsche Landesbank Girozentrale v Islington London Borough Council [Westdeutsche v. Islington BC(1996) A. C. 669], as follows: a) in cases where a total or partial payment is made by A to B of a property in the name of B or in both A and B. A rebuttable presumption arises that the property or money is a resulting trust held for A or if property is under the names of both A and B, then in shares equivalent to the amount they have contributed. (Wilson 2007, p. 151). This presumption can be refuted by a presumption of advancement or evidence that A actually intended a transfer and b) when by virtue of an express trusts; the entire beneficial interest is not conveyed or transferred (Wilson 2007, p. 151). According to Megarry J. in the case of Re Vandervell’s Trusts (No. 2), the second type is an automatic resulting trust. However, it is should be stressed that resulting trusts are presumptions which arise due the absence of intentions and not imposed by law which in effect are constructive trusts (Wilson 2007, p. 151). For instance in the case of Re West Sussex Constabulary’s Widows, Children and Benevolent Fund Trusts, it was ruled that should the person abandons his beneficial interest in a trust property, the beneficial interest over the portion which was undisposed necessarily belongs to the Crown as â€Å"bona vacantia† [Re West Sussex Constabulary’s Widows, Children and Benevolent Fund Trusts (1971)] Ch 1]. The third type of resulting trusts is quistclose trust. The name originated from the case Barclays Bank Ltd. v. Quistclose Investments Ltd. [(1968) UKHL 4, (1970) A. C. 567]. Rolls Razor could not meet the dividend payment so it borrowed money from Quistclose Investments. This borrowed money was placed in a separate account at Barclays Bank which was opened specifically for the purpose of dividend payment. This dividend payment was not made and thereafter, Rolls Razor filed for voluntary liquidation. Both Barclays and Quistclose Investments filed a claim. The House of Lords ruled that the amount of money in the special account belonged to Quistclose because it was in the nature of a resulting trust [Barclays Bank Ltd. v. Quistclose Investments Ltd. (1968) UKHL 4, (1970) A. C. 567]. The requisites for a quistclose trust to exist: â€Å"the loan is for a specified purpose and does not create a trust in favor of the recipient and the lender does not retain full equitable ownership of it because it is transferred to the recipient upon the condition that it shall be used only for the specified purpose;† should the purpose fail, a resulting trust is created in favor of the lender; and, (Chambers 1997, p. 68). There are two level of trusts structure, i. e. primary which refers to the payment of the loan for the specified purpose and the secondary trust level which refers to the trust in favor of the lender should the loan be not used according to the specified purpose [Barclays Bank Ltd. v. Quistclose Investments Ltd. (1968) UKHL 4, (1970) A. C. 567]. Another case to illustrate the point is Twinsectra v Yardley, the moneys borrowed from Twinsectra for Yardley with an undertaking of the solicitor of Yardley was for the purpose of purchasing a property but the moneys were not applied to said purpose and thereafter Twinsectra sought to recover the loss. Lord Millett made a lengthy discussion of the quistclose trust that it is not contractual but fiduciary. It creates a primary and secondary trust. The lender acquires beneficial interest over the money subject to the condition that it shall be applied for the specified purpose [Twinsectra v Yardley (2002) UKHL 12]. Analysis & Conclusion The presumptions described above arise when there is no evidence from which the intentions of the parties can be inferred. These presumptions have been criticized as being outmoded and not in keeping with the realities of the times. One of the criticisms is the use and application of ‘imputed’ in intention. In the Pettitt case as well as in Gissing v. Gissing, a majority expressed dissent and rejection over the use of imputation and suggested the use of ‘inference’ [Stack v. Dowden (2007) UKHL 17, (2005) EWCA Civ 857, s. 125]. Inference refers to an objective deduction of the actual intent of parties given the acts and circumstances while an imputed intention is â€Å"one which is attributed to the parties, even though no such actual intention can be deduced from their actions and statements, and even though they had no such intention. Imputation involves concluding what the parties would have intended, whereas inference involves concluding what they did intend† [Stack v. Dowden (2007) UKHL 17, (2005) EWCA Civ 857, s. 126]. The presumption of advancement has been criticized as being anachronistic and weak [Pettitt v. Pettitt (1970) AC 777 p. 824]. Lord Diplock explained that it no longer finds relevance in the modern genre as it can only find application during the 19th century of the propertied classes while Lord Hodson opined that it may only be of some use when there are no living witnesses from which inferences can be made of the intent of the parties [Pettitt v. Pettitt (1970) AC 777 p. 811]. It also has been rejected as one which is gender biased. The presumption of advancement is grounded on situation where gifts are transferred by the father, fiance (male to the daughters, wives (female) and does not provide the reverse but possible situations. In fact, it was further criticized as being in contravention of the Seventh Protocol to the European Convention on Human Rights relative to equality of rights and responsibilities between spouses and their children including the enjoyment of these rights without discrimination based on sex (Law Commission 2008, p.2-3). There have been moves made by the UK government to abolish the presumption but the proposed bill did not get to the second reading (Law Commission 2008, p. 3). The presumption of advancement was also criticized for perpetuating illegal transactions. As in the case of Tinsley v Milligan, where spouses jointly bought a house but the title was placed under the name of one of them so that the other can collect social security benefits. When both separated, the House of Lords applied the presumption of resulting trust [Tinsley v Milligan (1994) 1 AC 340]. Another issue is the beneficial interest. Dr. Chambers, in his book Resulting Trusts believes that beneficial interest is in the borrower because the lender has neither intention to transfer the entire beneficial interest nor the intention to retain it and considering that the transfer of beneficial interest is not in its entirety, the resulting trust is the default trust [Twinsectra v Yardley (2002) UKHL 12]. The Court of Appeal in the Twinsectra case holds the belief that the beneficial interest is in suspense. Both analyses cannot however explain the reason why the Court of Appeal allowed proprietary relief/remedy against the recipient of the misapplied funds unless the funds belonged to Twinsectra even before the misapplication; otherwise, there is no logical explanation for allowing remedy in favor of the third parties [Twinsectra v Yardley (2002) UKHL 12. An analysis of the explanation of Wilberforce L. in the Barclays case of primary and seconday trusts reveals that the resulting trust will arise only after the moneys have been used for another purpose other than the one specified and consequently, the lender’s interest to secure the moneys will be after the breach of contract. Therefore, it can be said that the interest of the lender to secure the moneys would be too late for certain circumstances. The resulting trust only arises when the loan is misapplied or paid for a purpose other than the specified purpose. However, insolvency can be possible to occur and pre date this breach of contract. By following Wilberforce’s interpretation, the lender cannot make a claim of resulting trust because his security interest has not yet arisen (Hudson 200 p. 6). On the other hand, the Twinsectra case, Millet’s L. version is that equitable interest is retained through out the period of the contract of loan. This is precisely an express trust where the lender retains equitable interest from the time the loan is entered into therefore he has security of interest even before the breach of the contract (Hudson 200 p. 6). This however, involves retention of title which destroys the essence of a resulting trust. The preferred analysis would be that it should be an express trust. However, the UK judicial system has not enunciated this principle in a case before it. It was only in Australia that this was made (Hudson 200 p. 8). Much is to be desired in the reform of resulting trusts that the Law Reform would need to address in terms of legislation and its effects on other cases. Reference List Barclays Bank Ltd. v. Quistclose Investments Ltd. (1968) UKHL 4, (1970) A. C. 567, viewed 23 March 2008, Barry, R and Cassell, E 1999, Trusts and family home: resulting trusts. University of Essex, viewed 21 March 2008, < http://www. luiss. it/erasmuslaw/uk/Ingh5. html> Chambers, R 1997 Resulting trusts, Oxford University, Clarendon Press, pp. 1-45. Hudson, A 2006 Fundamental of quistclose trusts, viewed on 24 March 2008, Law Commission 2008, Presumption of advancement: does it have any effect in practice? Law Commission Law Reform UK web site, viewed on 23 March 2008, < http://www. lawcom. gov. uk/docs/presumption_of_advancement. pdf. > Lloyds Bank Ltd v Rosset (1991), 1 AC 107, viewed on 21 March 2008, http://www.bailii. org/uk/cases/UKHL/1990/4. html Martin, J 1993, Hanbury and Martin: Modern equity, 17th edn, London, Oxford University, pp. 1-226. Pettitt v. Pettitt, [1969] UKHL 5 (23 April 1969), viewed on 21 March 2008, http://www. bailii. org/cgi-bin/markup. cgi? doc=/uk/cases/UKHL/1969/5. html Stack v. Dowden (2007) UKHL 17, (2005) EWCA Civ 857, viewed on 23 March 2008, http://business. timesonline. co. uk/tol/business/law/article1704361. ece Tinsley v Milligan (1994) 1 AC 340, (1993) UKHL 3, viewed on 23 March 2008, < http://www. bailii. org/cgi-bin/markup. cgi? doc=/uk/cases/UKHL/1993/3. html> Todd, P 1998, Introduction: resulting trusts. Our World web site, viewed on 21 March 2008, http://ourworld. compuserve. com/homepages/pntodd/trusts/informal/res_tr. htm Twinsectra v Yardley (2002) UKHL 12 UK Parliament web site, viewed on 23 March 2008 < http://www. publications. parliament. uk/pa/ld200102/ldjudgmt/jd020321/yardle-1. htm> Wilson, S 2007, Todd & Wilson’s Textbook on Trusts, Eighth edn. , London, Oxford University Press, pp. 150-152. Westdeutsche Landesbank Girozentrale v Islington London Borough Council (1996) A. C. 669, (1996) UKHL 12, viewed on 24 March 2008, http://www. bailii. org/uk/cases/UKHL/1996/12. html

The Mystery of Law School Application Essay Samples Nobody Is Talking About

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Napoleons Height Revealed

Napoleon Bonaparte (1769–1821) is chiefly remembered for two things in the English-speaking world: being a conqueror of no small ability and for being short. He still inspires devotion and hatred for winning a series of titanic battles, expanding an empire across much of Europe, and then destroying it all as a result of a failed invasion of Russia. A magnificent disrupter, he continued the reforms of the French Revolution (arguably not in the spirit of the revolution) and established a model of government which remains in some countries to this day. But for better or worse, the most famous thing most people believe about him is still that he was short. Was Napoleon Really Unusually Short? It turns out that Napoleon wasnt particularly short at all. Napoleon is sometimes described as being 5 foot 2 inches tall, which would definitely make him short for his era. However, there is a strong argument that this figure is wrong and that Napoleon was actually about 5 foot 6 inches tall, no shorter than the average Frenchman.   Napoleons height has been the subject of many psychological profiles. He’s sometimes cited as the chief example of short man syndrome, also known as a Napoleon complex, whereby short men act more aggressively than their larger counterparts to make up for their lack of height. Certainly, there are few people more aggressive than a man who defeated his rivals time after time across almost an entire continent and only stopped when dragged to a very small, far away island. But if Napoleon was of average height, the easy psychology doesnt work for him. English or French Measurements? Why is there such a discrepancy in historic descriptions of Napoleons height? As he was one of the most famous men of his era, it would seem reasonable to assume that his contemporaries knew how tall he was. But the problem may have been due to a difference in measurements between the English and French-speaking worlds. The French inch was actually longer than the British inch, leading to any height sounding shorter to the English speaking world. In 1802 Napoleons doctor Jean-Nicolas Corvisart-Desmarets (1755–1821) said Napoleon was 5 foot 2 inches by the French measure, which equates to about 5 foot 6 in British measurements. Intriguingly, in the same statement, Corvisart said that Napoleon was of short stature, so it may be that people already assumed Napoleon was small by 1802, or that people assumed the average Frenchmen was much taller. The Autopsy Matters are confused by the autopsy, which was carried out by Napoleon’s doctor (he had numerous doctors), Frenchman Franà §ois Carlo Antommarchi (1780–1838), who gave 5 foot 2 as his height. But was the autopsy, which was signed off by a number of British doctors and in a British owned area, in British or French measures? We don’t know for sure, with some people adamant the height was in British units and others French. When other sources are factored in, including another measurement after the autopsy in British measurements, people generally conclude with the height of 5 foot 5–7 inches British, or 5 foot 2 in French, but there is still some doubt. Le Petit Caporal and Larger Bodyguards If Napoleons lack of height is a myth, it may have been perpetuated by Napoleon’s army, because the emperor was often surrounded by much larger bodyguards and soldiers, giving the impression of him being smaller. This was especially true of the Imperial Guard units which had height requirements, leading to them all being taller than him. Napoleon was even named the le petit caporal,  often translated as little corporal, even though it was a term of affection rather than a description of his height, further leading to people assuming he was short. The idea was certainly perpetuated by the propaganda of his enemies, who portrayed him as short as a way of attacking and undermining him. Sources Corso, Philip F., and Thomas Hindmarsh. Correspondence RE: Napoleons Autopsy: New Perspectives. Human Pathology 36.8 (2005): 936. Holmberg, Tom. First-Hand Descriptions of Napoleon. The Napoleon Series, 2002  Lugli, A., A. Kopp Lugli, and M. Horcic. Napoleon’s Autopsy: New Perspectives. Human Pathology 36.4 (2005): 320–24. Print.Jones, Proctor Patterson. Napoleon: An Intimate Account of the Years of Supremacy 1800–1814. New York: Random House, 1992.