Oscar Chess v Williams, the facts, reasoning and appeal

Oscar Chess v Williams, the facts, reasoning and appeal Oscar Chess Ltd v Williams [1957] 1 ALL ER 325 What were the material facts of the case and the legal issues on which the appeal was based? In June 1955, the defendant sold to the plaintiff, who were motor dealers, a second-hand Morris motor car for  £290, this sum being credited to the defendant on the purchase of a new car through the dealers. The car sold to the dealers had been obtained by the defendant’s mother in 1954 under a hire-purchase contract, and was shown in the registration book to have been first registered in 1948. There had been five changes of ownership between 1948 and 1954. The defendant, who honestly believed that the car was a 1948 model, described it as such to the salesman who acted for the plaintiffs in the matter and showed the salesman the registration book. The salesman, who had frequently been given lifts in the car, also believed that it was a 1948 model, and the purchase price of  £290 was calculated on this basis. In January 1956, the plaintiffs sent the chassis and engine numbers of the car to the manufacturers and were informed by them that the car was a 1939 model. If the pl aintiffs had known at the time of the purchase that the car was a 1939 model, they would have paid only  £175 for it. In an action brought by them against the defendant eight months after the sale the plaintiffs claimed the sum of  £115 as damages for breach of warranty, either on the basis that it had been a condition,[1] i.e. an essential term, of the contract that the car was a 1948 model or that there had been a collateral warranty that it was. The judge at trial awarded the plaintiffs  £115 in damages based on his finding that the defendant had breached an essential term of the contract, i.e. a condition, that the Morris car was a 1948 model. Consequently, the trial judge did not go on to consider the alternative claim on a warranty. Upon appeal by the defendant, the crucial issue for the Court of Appeal was whether the defendant’s statement that the car was a 1948 model was a binding promise (i.e. a contractual term) or only an innocent misrepresentation. If it was an innocent misrepresentation, the respondent would not be entitled to any remedy. What was the reasoning behind the trial judge’s decision to award damages to the plaintiffs? At trial, the plaintiffs claimed the sum of  £115 in damages from the defendant, representing the difference in value between a 1939 Morris car and a 1948 Morris car. The evidence submitted at trial to determine whether the defendant gave a binding promise to the salesman that the car was made in 1948 was limited. During examination-in-chief, the salesman stated: â€Å"He offered me a 1948 10 hp Morris in part exchange. He produced the registration book.† In cross-examination, he said: â€Å"I had often had lifts in the defendant’s car. I thought it looked like a 1948 model. I checked up in the registration book.† The salesman’s evidence was accepted, aided by the fact that the defendant did not go into the witness-box to contradict it. On those facts alone, counsel for the plaintiffs submitted that the defendant’s representation that the car was a 1948 model was an essential term of the contract, i.e. a condition. The trial judge agreed with this and stated that defendant had promised that the car was a 1948 car and that there was a breach of this promise. He said that the allowance of  £290 was made by the salesman â€Å"on the assumption that the Morris was a 1948 model†, and that â€Å"†¦this assumption was fundamental to the contract, a condition which, if not satisfied, would have caused him to rescind the contract if he had known it to be unsatisfied before the property in the Morris car passed to his principles.† In short, one of the terms of the deal was that the car was guaranteed to be a 1948 model. Breach of this promise would entitle the dealer to damages. Based on this finding, the trial judge awarded  £115 in damages to the plaintiffs. Why did the Court of Appeal overrule the trial judge’s decision and what was the difference in approach adopted by the Court of Appeal? The Court of Appeal refused to get bogged down in a technical differential analysis of the legal definitions of â€Å"condition† and â€Å"warranty†, as the trial judge had done, because it was far too late for the buyer to reject the car. He could only claim damages at best. Indeed, in the Court’s leading judgment, Denning LJ stated that the trial judge was so concerned with the legal definitions of â€Å"condition† and â€Å"warranty† that he failed to address the crucial issue of whether the defendant’s statement was a term of the contract at all. To get damages, it was necessary to show that the description of the car was a promise or term of the contract. Denning LJ used slightly different language. He used the word warranty but he explained that he was not using the word in its technical legal sense but, instead, was using it in its popular sense as one word to describe a promise. As he pointed out, the crucial question in this case was : was it a binding promise [i.e. a term of the contract] or only an innocent misrepresentation? If it was only an innocent misrepresentation, then the dealer would not be entitled to any remedy in the circumstances of this case. This then leads to the question: how do you know if it was a promise? Denning LJ stated that whether the appellant’s statement was intended to be a promise (i.e. a contractual term) could only be addressed by taking into account all the evidence of the case and the conduct of the parties throughout their dealings.[2] He went on to state that the objective test for determining a promise is by applying the standard of the ‘intelligent bystander’ and, based on this test, he concluded that the statement by the appellant as to the age of the car was not intended as a promise. After all, given that the appellant only became the owner after several changes in ownership, he must have been relying on what was stated in the registration book. It is unlikely that such a person would warrant the year of manufacture. The most that he would do would be to state his belief, and then produce the registration book in verification of it. In these circumstances, according to Lord De nning, the intelligent bystander would say that the seller did not intend to bind himself so as to warrant that the car was a 1948 model. The most he would do would be to state his belief. What did the Court of Appeal say about the trial judge’s application of the earlier decisions in Heilbut2 and Routledge[3]to the present case? In finding in favour of the appellant, Denning LJ made reference to the case of Heilbut in which the House of Lords used the word â€Å"warranty† in its ordinary meaning of a binding promise. He stressed that, in Heilbut, Lord Moulton made it clear that â€Å"The intention of the parties can only be deduced from the totality of the evidence†¦Ã¢â‚¬  In other words, to determine whether a statement was intended as a contractual warranty, it is necessary to evaluate the overall conduct of the parties, not just their thoughts. However, the trial judge did not adopt this approach and distinguished Heilbut and Routledge on the basis that, in those cases, there was a written memorandum of the contract, before which words were used by one party inducing the other party to enter into the contract. Denning LJ stated that there was no need to distinguish between written and oral statements in the present case because the purchase was not recorded in writing at all but, instead, it was necessary to look at the overall conduct of the parties in order to ascertain intention. Hodson LJ, in accordance with Denning LJ, felt that the Routledge decision should not be distinguished from the present case because, in his opinion, the court in the Routledge case did not base its decision on the distinction between words used before the conclusion of the contract and words used at the time of the contract. He felt that this distinction was a fine point and had no bearing in the current case. Instead, Hodson LJ concurred with Denning LJ and stated that it was necessary to follow the principle in Heilbut and assess the overall conduct of the parties in order to ascertain contractual intention. Morris LJ (dissenting), on the other hand, supported the reasoning of the trial judge and felt that the judge was correct to distinguish Routledge from the current case. He specified three grounds for the distinction: (i) in the present case there was a statement made at the time of the transaction; (ii) there was no written contract; and (iii) although there was no contract, there was an invoice addressed to the appellant which expressly described the car as a â€Å"1948 Morris 10 Saloon†. He felt that the fact that the invoice specifically referred to the year 1948 was sufficient evidence that it was intended to be a contractual term. What is the significance of the respective parties’ special knowledge of the subject-matter of the contract? How has this been applied in this and subsequent cases? Another influential factor in this case was that the person making the statement (i.e. the appellant) was a non-expert when compared with the dealer who was the recipient of the statement and, presumably, an expert. According to Denning LJ, the respondents, rather than simply relying on the year stated in the log-book, could quite easily have checked it at the time of sale by taking the engine number and chassis number and writing to the manufacturers. They only did so eight months after the sale. Given that the respondents were experts, Denning LJ felt that this delay in making the check could not be excused, particularly because the innocent appellant produced to them all the evidence which he had (namely, the registration book). The appellant, as a private seller, had no special knowledge and had relied on the car’s registration book for his belief. The respondents, as experts, were in a position to discover the truth of the statement prior to contract. Hodson LJ agreed wit h this point and stated that the appellant was stating an opinion on a matter of which he had no special knowledge, whereas the respondent could have been expected to have an opinion and to exercise its judgment. This tends to support the view that the non-expert would be unlikely to be promising something which was in the other partys area of expertise, and therefore strengthens the proposition that the appellant’s statement was indeed a representation and not a contractual term. The significance of a parties â€Å"special knowledge† was considered by the Court of Appeal in the subsequent case of Dick Bentley Productions and Another v Harold Smith (Motors) Ltd.[4] In that case, a car dealer stated that a car had an engine which had done only 20,000 miles. This was in fact untrue. The buyer sought damages alleging breach of contract. However, in that instance, the statement was treated as a term of the contract. The apparent distinction between the Dick Bentley case and the Oscar Chess case is the status of the person making the statement. A private seller did not have the special knowledge which indicated an intention that the statement be treated as a contractually binding promise, but a car dealer did. This distinction led Lord Denning MR to suggest in Dick Bentley that the presence of fault was the basis for the distinction. However, it seems wrong to suggest that fault is the only test, and arguably what Lord Denning was stating was simply that the obligation broken was an obligation to exercise reasonable care and skill. The true test ought therefore to be that the dealer was in a better position to discover the truth and therefore impliedly took personal responsibility for the truth of statements made. Why did dissenting Judge Morris LJ disagree with the conclusion of the majority of the Court of Appeal? Morris LJ disagreed with the findings of Denning LJ and Hodson LJ and felt that the appellant’s statement that the car was a 1948 model was a fundamental term of the contract, i.e. a contractual condition. What persuaded Lord Morris was that the car was described in the invoice specifically as a 1948 Morris. The dealer did not get any such thing and so, according to Lord Morris, there was a breach. He arrived at this conclusion based on his assertion that the respondent’s promise to pay the appellant  £290 for the car (a figure arrived at by reference to the value of 1948 cars) was the consequence (i.e. a counterpart) of a term of the contract that the particular car was a 1948 model. Thus, Morris LJ felt that the application of the so-called ‘importance attached’ test rendered the appellant’s statement a term of the contract for sale as opposed to a mere representation. In other words, Morris LJ believed that the appellant’s statement relat ed to a vitally important matter: it described the subject-matter of the contract then being made, and directed the parties to, and was the basis of, their agreement as to the price to be paid or credited to the respondent. He made reference to the words used by Scott LJ in Couchman v Hill[5] and stated that, in his opinion, the appellant’s statement was â€Å"an item in [the] description† of what was being sold and that it constituted a substantial ingredient in the identity of the thing sold. Whereas Denning LJ felt that the trial judge was unnecessarily bogged down with the technical legal translation of â€Å"condition† and â€Å"warranty†, Morris LJ stressed that he saw no need to depart from the original verdict because he could not see that the trial judge in any way misdirected himself or misapplied any principle of law. Bibliography Cases Consulted Oscar Chess Ltd v Williams [1957] 1 ALL ER 325 (CA); Dick Bentley Productions and Another v Harold Smith (Motors) Ltd [1965] 2 All ER 65 (CA); Couchman v Hill [1947] 1 All ER 103 (KB); Heilbut, Symons Co v Buckleton [1913] AC 30 (HL); Routledge v McKay [1954] 1 All ER 855 (CA). Legislation Consulted Sale of Goods Act 1893 (22 Halsbury’s Statutes (2nd Edition) 991). Text Consulted Poole, J. – Textbook on Contract Law (6th Edition), Blackstone Press (2001), pp155-6; Poole, J. – Casebook on Contract (4th Edition), Blackstone Press (1999), pp249 and 252-4. 1 Footnotes [1] Under section 11 of the Sale of Goods Act 1893 (22 Halsbury’s Statutes (2nd Edition) 991), the plaintiffs would have been entitled to treat such a condition as a contractual warranty, breach of which would give rise to an action for damages. [2] Heilbut, Symons Co v Buckleton [1913] AC 30 (HL). [3] [1954] 1 All ER 855 (CA). [4] [1965] 2 All ER 65 (CA). [5] [1947] 1 All ER 103 (KB).

The Subtleties of Men and Women :: essays research papers

There are many things to be said about men and women. No one can pretend they know everything about the two. A vast majority of people want to study the relationship between men and their counterparts. One could say that it is made too complicated when it starts when it starts getting into the psychoanalytical studies. Men are put out there as more dominant leaders, and women and women start to feel like they have something to prove to society by proving they too can do just as well. Being that by nature human beings are subject to their own greed, thus women will go to great lengths to prove they can do as men do. The Civil Rights Act was extended towards women too. As a result of that it opened the door for women for women to participate in more things only men were allowed. Some men and women do not even get along. Perhaps to see and understand, certain differences should be looked at such as interest, hobbies, and habits. If the interests are looked at one would see they are clearly not the same. A typical male will have a favorite sports team in which he watches every game. There are many other interests like hunting, fishing, and just about any outdoor activity. A weekend well planned would consist of camping, fishing, and a nice fire at the end of the day. Generally, women would rather not watch football or basketball games. They would rather go to the mall and see what sales are going on. However there are some girls who would rather get dirty with the boys, as opposed to doing hair or having a sleepover. Men and women also have different hobbies. A man will get real involved with his car. He will want to modify the engine to make it faster. It is in a way competitive to do it on one’s own. Coming from man’s nature it is an exhilarating feeling to brag about what he has done with it. Also a man likes to brag about the deer he shot or the fish he caught. On the other side of the road man’s counterpart typically likes to plant flowers or do some sort of crafts. They would rather stay cleaner and engage in something that will not get them greasy. Maybe it is due to women having more patience or just that men do not see that as very masculine.

Essay on Internet Privacy - Ethical Issues Raised by Privacy Service Pr

Ethical Issues Raised by Privacy Service Providers      Ã‚  Ã‚  Ã‚   Abstract:   This paper examines the use of Internet technologies (specifically SafeWeb.com) to counteract invasions of personal privacy and censorship.   The paper begins by exploring the methods by which governments, corporations, and commercial agents invade personal privacy.   It also discusses Internet censorship on the corporate and governmental levels.   It then proceeds to discuss SafeWeb.com, a technology that allows Internet users to surf the Web privately and view censored content.   The paper finishes by exploring some of the ethical issues raised by Internet privacy and censorship in specific relation to SafeWeb, concluding that the application of SafeWeb in circumventing the authority of governments and corporations is inherently unethical.         Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Part of the allure of the Internet has always been the anonymity it offers its users.   As the Internet has grown however, causing capitalists and governments to enter the picture, the old rules are changing fast.   E-commerce firms employ the latest technologies to track minute details on customer behavior.   The FBI's Carnivore email-tracking system is being increasingly used to infringe on the privacy of netizens.   Corporations now monitor their employees' web and email usage.   In addition to these privacy infringements, Internet users are also having their use censored, as governments, corporations, and other institutions block access to certain sites.   However, as technology can be used to wage war on personal freedoms, it can also be employed in the fight against censorship and invasion of privacy.      Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Network technologies have allowed for an unprecedented invasion of persona... ...nomist.com/displayStory.cfm?Story_ID=471742>. Cooper, Charles.   Saudi Arabia's Battle of the Bits.   2001.   ZDNet.   Feb. 20, 2001.   Tanaka, Jennifer.   The Secret (Server) Service.   2001.   AdWeek.   Feb. 20, 2001.   . The 20 Enemies of the Internet.   1999.   Radio Free Europe / Radio Liberty.   Feb 20, 2001.   . Sussman, Leonard R.   The Internet and Press Freedom 2000.   2000.   Freedom House.   Feb. 20, 2001.   . Graham, Robert.   Carnivore FAQ.   2000.   Feb. 20, 2001.   . Conrey-Miller, Andrew.   The Pros and Cons of Employee Surveillance.   2001. Feb. 20, 2001. .

Romans 14 Essay -- The Book of Romans

The book of Romans was written by Paul. It is actually a letter that Paul wrote to the Romans telling them about his understanding of the Gospel. In this book his explains our sins and how we can achieve forgiveness through Christ. The most specific sin that he explains is that of judging one another. He helps address the problem of religious disagreements about different customs or religious convictions. These customs or religious convictions include the days on which people worship the Lord and the things that people will and will not eat. He wrote about the fact that we should not judge each other for God is going to judge us all in the end. "For this very reason, Christ died and returned to life so that he might be the lord of both the dead and the living." (Ro 14:9). The first distinction I want to make about this passage is the wording Paul used to describe Christ. He states that Christ died and than lived. His resurrection is what gives Him grounds to rule over the living and the dead. His power is as mighty in the living world as it is in the afterlife. We are never going to be on our own for he is there to reign over us for all of eternity. "You, then, why do you judge your brother? Or why do you look down on your brother? For we will all stand before God's judgment seat." (Ro 14:10). Paul is saying that we should not look down upon or judge a fellow believer. If what they are doing is truly in worship of the Lord, then who are we to judge them as though they are the ones who are wrong? The choices that he is dealing with are those of many people's religious traditions. One of these is the choice of which day different believers decide to worship the Lord. The other is whether or not a perso... ...he one who is going to judge us all in the end. Paul is letting us know that who we judge and how we judge them is going to be the same way that we are going to be judged on our day of reckoning. Everyone shall give an account of his life to the Lord. (Ro 14:12) This ending verse is basically a summary of what Paul has been writing about through most of chapter 14. It is there to say that in the end we will not be the ones who judge each other. Whether or not I have passed my judgment upon you in life will have no bearing on what happen to you in the afterlife. The same goes for if you are to pass your judgment on me. Our judgments have no affect on each other once we are brought before the Lord on our day of judgment. I will not be there to judge you and you will not be there to judge me. The Lord is going to be there to judge us all for our lives.

Death of A Salesman :: essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Biff / Willy - Turning Points   Ã‚  Ã‚  Ã‚  Ã‚  A major turning point in the story Death of a Salesman occurs on pages 1394 and 1395. The scene is Willy walking into Charley’s office and he sees Bernard (Charley’s son) waiting in the waiting room. Willy sits next to Bernard and starts to have a conversation with him. The conversation starts out casual, then Willy asks Bernard where did he go wrong with Biff (Willy’s son). Bernard tells Willy that Biff was prepared to attend summer school and Willy was surprised. Bernard asks Willy if Biff came up to see him in New England. Willy replied, â€Å"Yeah, he came to Boston. What about it?† He tells Willy that when Biff came back he wasn’t the same and it was then that Bernard knew that Biff had given up his life. When Bernard asked Willy what happened up there Willy got angry and said that nothing happened. After that conversation Willy started to play back in his mind the events that occurred the day Biff came to see him in Boston. On page 1407 Willy is in the hotel room with his mistress and they hear a knock at the door. The woman tells Willy, â€Å"Aren’t you going to answer the door? He’ll wake the whole hotel.† After trying to divert her attention Willy tells the woman to hide in the bathroom while he answers the door. Willy opens the door and sees Biff standing there. He asks his son why he came to Boston and his son replies that he flunked math and doesn’t have enough credits to graduate. They talk a little more then a laugh is heard from the bathroom. The woman comes out of the bathroom and Willy tries his best to get rid of her. He tells Biff that she just needed to borrow his shower. Tears begin to fall down Biffs face and Willy is still trying to come up with excuses.

Roman Polanskis Repulsion Essay -- Film Movies

Roman Polanski's Repulsion Analysis of an aspect of visual form in the film ‘Repulsion’ In the 1964/65 film ‘Repulsion’ by Roman Polanski, the story is about the conflict between reality and fantasy or sanity and insanity inside the main character’s mind – Carol played by Catherine Deneuve. Therefore the narrative technique of symbolism is used to display visually to the film’s audience what happens to Carol’s mind. In this particular instance, the degeneration of Carol’s state of mind is symbolised. Carol’s state of mind degenerates, or breaks down because of her repulsion of masculinity in a sexual context. Through Carol’s eyes, we see masculinity as being aggressive, obsessive, crude/sexually suggestive, rapacious and sinister, and although these are masculine traits, they are not a full representation of males/masculinity in society. Therefore one can see that Carol has misunderstood and become very wary of men. She is a very pretty woman and the film uses her to display an almost stereotypical femininity – weak/ fragile and delicately featured – ironically, the complete opposite to Carol’s own view of men. And so, overall, the film basically represents male domination and female vulnerability. Also to highlight the difference between Carol’s reactions to men and her reactions to women, the writer has chosen to place her character in a beauty parlour. This is used to represent a pleasant but superficial world against a nasty one – through Carol’s eyes that is. From the beginning, one can tell that there are going to be elements of surrealism in the film by the style in which the credits are run. These opening credits run generally upwards (I say generally as some of the credits are at angles – but still maintaining an ‘upward-ish’ direction) over an extreme close-up shot of Carol’s face, and also some credits finishing on-screen at her top eyelids whereas some finish by running off-screen. During the film, we see Carol go to work at the beauty parlour. By the camera-man shooting over her shoulder, a personal view of her life and how she sees life around her. If the camera was used as her eyes, it would have made these scenes too subjective and too unsubtle. We can therefore look at the same things as Carol, but for our own sakes, though this does leave a certain ambiguity. For example, when Carol walks to work, she looks at an empty, da... ...late with the rotting rabbit and the cut-throat razor on it. This could symbolise that she is on the ‘razor’s edge’ and that it is rotting her mind away. It is unclear why Carol has become repulsed by men and sex. It is suggested that it is to do with something or even someone in her past, e.g. she might have been sexually abused by an older person. Maybe that is why she is repulsed by the landlord and in her irrationality, she attacks him. She also regards the photo of her when she was young with happiness. That, along with the bells and the sound of girls running around dubbed over the film at that point, could suggest that she went to a convent school, which are all girls, and therefore makes her feel safe and protected, as the beauty parlour does. Carol’s neurosis of life might be that she see men as sexual objects only, not as real people, and so she is repulsed. Then one can ask, why is she repulsed by this? And the only possible answers are that she might have been abused in her childhood, or something else deep and psychological of a very sexual nature affected her back then. But it is extremely hard to say exactly what, since we are never shown any part of her past.

Imprisonment and Social Control Essay -- Prison Justice

Imprisonment is one of the primary ways in which social control may be achieved; the Sage Dictionary of Criminology defines social control as a concept used to describe all the ways in which conformity may be achieved. Throughout time imprisonment and its ideas around social control have varied. Imprisonment has not always been used for punishment, nor has it always thought about the prisoners themselves. However when looking at imprisonment it is important to consider the new penology. Therefore, it needs to be clear what the new penology is. The new penology is said, not to be about punishing individuals or about rehabilitating them, but about identifying and managing unruly groups in society. It is concerned with the managerial processes, not the individual’s behaviour or even community organisation. All in all, its goal is to make crime tolerable, not to eliminate it entirely. (Feeley, M and Simon, J). Therefore the New Penology is not about the reform of individuals but the control of populations as a whole, with imprisonment focusing on particular offenders who are defined as ‘persistent’ or ‘high rate’. In light of this, the history of imprisonment, the purposes of imprisonment and indeed the question of whether it works as a form of social control or not all need to be addressed, as well as looking into the critics of the new penology. Imprisonment has a number of purposes, the first being punishment, which brings with it the idea of retribution and revenge. The second purpose is incapacitation, this looks at the protection of society and the length of time the individual must serve in prison. Deterrence is the third purpose; it attempts to prevent the individual committing any future crime and goes some way to deter ... ...ology. Devon: Willan Publishing, pp 684-713. Sampson, R, and Laub, J. (1933), ‘Individual Factors in Crime’, in Newburn, T. Criminology. Devon: Willan Publishing, pp. 843. Shichor, D. (1997) ‘Three Strikes as a Public Policy: The Convergence of the New Penology and the McDonaldization of Punishment’, Crime Delinquency, (43), pp. 470-492. Spelman, W. (2000) ‘What Recent Studies Do (and Dont) Tell Us About Imprisonment and Crime’. In Michael, T. Crime and Justice: A Review of Research. (3). Chicargo: University of Chicargo Press. Wilson, D. (2006) ‘Social Control’, The Sage Dictionary of Criminology: 391-392. London: Sage Publications. Woolfe, H. And Tumim, S. (1991). ‘Official Aims of Imprisonment’, in Cavadino, M. and Dignan, J. The Penal System: An Introduction. London: Sage Publications. Zedner, L (2004). Criminal Justice. New York, USA: Oxford University.