Resulting trusts and voluntary conveyances of land

Considers whether the Law of Property Act 1925 s.60(3) prevents a resulting trust from arising on a voluntary conveyance of land. Examines modern case law considering the section, the position prior to its enactment and the possible interpretations of the section, preferring an interpretation which abolishes the previous doctrine of presumption of resulting use. Highlights the advantages of recognising that a resulting trust cannot arise on a voluntary conveyance of land

Prediction of working outcomes in trainee dogs using the novel Assistance Dog Test Battery (ADTB)

Canine behaviour is commonly assessed using test batteries comprising a test protocol and ethogram scoring system. These are particularly valuable for assistance dog organisations as a tool for evaluating trainee dogs’ proficiency in fundamental skills. The goal of this study was to design and validate a new test battery to assess the suitability of trainee dogs for assistance work at different stages of the training programme. The main objective was to develop a machine-learning tool capable of predicting working outcomes. Accordingly, the novel Assistance Dog Test Battery (ADTB) was developed. Trainee assistance dogs participating in this research performed the test at 3 weeks and 10 weeks after starting formal training. The results from the univariate logistic regression analysis were used to select the variables for the reduced feature sets that were used for modelling. The machine learning models were built using the data collected at 3 and 10 weeks separately and predicted working outcomes with an area under the ROC curve of 0.74 and 0.84, respectively. This research demonstrated the relationship between the novel ADTB ethogram measures and working outcomes in assistance dogs. The machine learning model created using the data collected at 3 weeks achieved comparable performance to the state-of-the-art, while the model built using the data collected at 10 weeks substantially outperformed it. These preliminary results suggest that the ADTB is a reliable tool for the prediction of working outcomes in trainee assistance dogs. Hence, assistance dog organisations can reduce the cost of training by using model predictions as a guide for deciding which dogs to withdraw from training. The data collected and the code developed in this research are publicly available on Mendeley Data (https://doi.org/10.17632/5mzfpt455r.1) and GitHub, respectively (https://github.com/mmarcato/dog_ethogram/)

Shakespeare and early modern Europe: A critical survey

This survey examines the history of criticism on Shakespeare and early modern Europe. With major sociopolitical European events in mind, the article reviews scholarship on this topic from the early twentieth century to the present day. Particular emphasis is placed on studies of Shakespeare’s own treatment of European characters and settings. The related topics of the changing meaning of “Europe” of Shakespeare’s European afterlives are also briefly discussed

How do mental health professionals use humor? A systematic review

Although the value of humor is appreciated in mental health care, little is known about how professionals employ humor. The purpose of this systematic review was to explore how mental health professionals use humor. Academic databases were systemically searched. Papers were subjected to quality appraisal. Ten studies met eligibility criteria. Mental health staff used humor to cope with stress and adversity. They also used humor to enhance relationships with service users, and to erode team-related power dynamics. It was suggested that knowing when to use humor appropriately was dependent on experience and how well staff knew service users. However, it was also found that staff’s use of humor was sometimes negatively perceived by service users, as it could reinforce power dynamics. Due to the limited and low level of evidence, it is recommended that rigorous research in the area of humor in mental health practice is undertaken

US efficient factors in a Bayesian model scan framework

Purpose: The author examines the impact these efficient factors have on factor model comparison tests in US returns using the Bayesian model scan approach of Chib et al. (2020), and Chib et al.(2022). Design/methodology/approach: Ehsani and Linnainmaa (2022) show that time-series efficient investment factors in US stock returns span and earn 40% higher Sharpe ratios than the original factors. Findings: The author shows that the optimal asset pricing model is an eight-factor model which contains efficient versions of the market factor, value factor (HML) and long-horizon behavioral factor (FIN). The findings show that efficient factors enhance the performance of US factor model performance. The top performing asset pricing model does not change in recent data. Originality/value: The author is the only one to examine if the efficient factors developed by Ehsani and Linnainmaa (2022) have an impact on model comparison tests in US stock returns

The limits of proprietary estoppel: Thorner v Major

Considers the House of Lords decision in Thorner v Major, reported as Thorner v Curtis, on whether a farmer who had worked without pay on his cousin's farm because of vague assurances that he would inherit the farm, had a claim in proprietary estoppel when the cousin died intestate. Discusses how the reasoning in the instant case differed from the earlier House of Lords decision in Cobbe v Yeoman's Row Management Ltd, the importance of certainty of representation and of the subject matter of the representation and the relationship between proprietary estoppel and constructive trusts

Porous privacies: Gender, migration, and precarious homes in early twenty-first century narrative films from the French Mediterranean

A prominent trope in so-called banlieue cinema—French cinema focused on housing projects on the outskirts of large French cities largely inhabited by migrants and their descendants—represents precarious migrant homes, and by extension entire neighborhoods, as dysfunctional and cut off from social life. This essay explores representations of precarious migrant homes that resist such polarising media images, and that insist on a porous privacy as a precondition for narrative and subjective development—for the ability to thrive—while pointing out the often gendered and precarious nature of such porosity. The natural and built specificities of the Mediterranean coast have often provided a productively rich set for such revisions, including for auteurs such as Claire Denis and Abdellatif Kechiche to develop their distinctive styles. Lesser-known filmmakers, such as Bania Medjbar and Hafsia Herzi, emerge in the wake of earlier revisionist films. Less focused on developing distinctive styles, they are invested in character-driven stories, and on stories that feature a range of characters and thus narrative options, while pointing out the gendered complexities of precariously porous homes

Teaching tip: Embedding sustainability in information systems design education

Sustainability refers to the achievement of present needs without compromising the ability of future generations to meet their own needs. While prior research has highlighted the potential of Information Systems (IS) to support sustainability objectives - for instance, through supporting eco-efficient work practices and democratising healthcare access - our understanding of how to integrate the United Nation’s Sustainable Development Goals (SDGs) as a core aspect of IS teaching and curricula remains nascent. This teaching tip presents a pedagogical design and teaching method for embedding sustainability in systems design education using design thinking and ‘active learning’ techniques. We provide examples of how students translated the SDGs into design concepts that target real-world sustainability problems with feedback from subject matter experts. Recommendations are then provided for supporting students’ experiential journeys when exploring sustainability objectives in the classroom by providing opportunities for variation and experimentation

Proprietary estoppel, promises and mistaken belief

This chapter considers the restrictive vision of proprietary estoppel put forward by Lord Scott and Lord Walker in the House of Lords in Yeoman’s Row v Cobbe [2008] UKHL 55. It explains that the impact of taking their arguments seriously would be the elimination (or, at least, the severe restriction) of one of the three distinct principles subsumed within proprietary estoppel, ie the promise principle stated by Lord Kingsdown in Ramsden v Dyson. The chapter suggests that, although the approach in Cobbe runs counter to the current of equitable development over the last forty years, it does highlight important issues of principle surrounding the scope of proprietary estoppel. Despite the tendency to downplay the role of promise within the doctrine, the pre-Cobbe version of proprietary estoppel ventures into the territory of the law of contract, doing so only in respect of promises related to land/property (without any convincing justification as a matter of principle for this restriction). Rather than seek to deal comprehensively with the very large question as to the merits or otherwise of Lord Kingsdown’s promise principle, this chapter seeks to address a more modest set of questions. First, it points out that the particular concern which seems to have animated the judges in Cobbe – that it is wrong to allow C to succeed on the basis of a promise which C knows is binding only in honour – can be accommodated within the conventional modern understanding of proprietary estoppel, without any need to eliminate or severely curtail Lord Kingsdown’s principle. Secondly, the chapter addresses the seductive suggestion that a distinction should be drawn between the commercial and the domestic contexts, with the restriction upon proprietary estoppel suggested in Cobbe applying only in the commercial context. It concludes on the basis of a number of different arguments, that this suggestion does not represent a desirable avenue of development for the law. One of the points made against any application of a mistake requirement in the context of the promise principle is that this requirement makes sense only in the context of the acquiescence principle; the suggestion that it should be applied more broadly appears reminiscent of attempts in the past to apply the probanda to all proprietary estoppel cases. In terms of the future development of the law of estoppel, what is needed is a willingness to separate out for analysis the distinct principles which have, for historical reasons, been grouped together under the heading of proprietary estoppel. The emphasis on ‘unconscionability’ and ‘synthesis’, encouraged by the overrated judgment of Oliver J in Taylor Fashions, have contributed to the current confused state of the law. Following the debacle represented by Cobbe, it is time for a somewhat more reflective approach