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Torts (Interference with Goods) Act 1977
Here is where you can learn more about Abandoned Goods. Most landlords will experience items of property or in legal terms ‘chattels’ that are left behind after the tenancy ends and the Tenant vacates the property.
The law governing this situation is the Torts Interference with Goods Act 1977 Chapter 32 [known as TIGA 1977] Section 12. ‘Bailee’s power of sale’ being relevant to landlords.
Much is written but not such that summarises all relevant cases and gives pragmatic advice to landlords. On the one hand, a landlord primarily is often at a loss. Otherwise they would probably be able to seek remedy against the holding deposit (providing the tenancy agreement provides for this).
On the other hand, there are legal sanctions against a landlord if they don’t act in accordance with the law. This explains the law and how a landlord can work with this to minimise their voids and financial losses.
‘WRONGFUL INTERFERENCE’ with goods – where
‘CONVERSION’ – taking over the rights of / treating as the owner. Also called ‘Trover’ – the legal right to damages for the value of property appropriated by another.
‘TRESPASS TO GOODS’ – can be as little as touching or moving the goods. If a tenant is in rent arrears, most landlords will know that it is not legal to seize any of their belongings. Or to retain, or hold onto them in lieu of a debt.
‘DISTRESS’ – this common law remedy was abolished by the Tribunals Courts and Enforcement Act, 2007 Sec 71
‘DETINUE’ – action by the owner to recover possession from another in whose custody the goods remain was abolished by TIGA. It is now dealt with by ‘Conversion, and Trespass to Goods’
‘BAILOR’ – legal owner of the abandoned goods (in this case, Tenant)
‘BAILEE’ – a person who has [temporary] possession of the abandoned goods (i.e. Landlord. See later examples).
TIGA Sec 12 Uncollected Goods applies to goods in possession of a ‘Bailee’, where:
- If the ‘Bailor’ is in breach of obligation to take delivery of the abandoned goods. If terms of bailment so provide. Or to give directions as to their delivery. Or…
- A ‘Bailee’ could impose such conditions by giving notice but is unable to trace or communicate with the bailor. Or…
- You can reasonably expect a ‘Bailee’ to be relieved of any duty to safeguard the abandoned goods on giving notice – but is unable to trace or communicate with the ‘Bailor’.
‘Bailor’ and ‘Bailee’ Communication
Schedule 1, Part 1 of TIGA. Allows for a ‘Bailee’ to impose an obligation on the ‘Bailor’ to take delivery of the goods. Or give directions as to their delivery and sets out the method of notification.
If the ‘Bailee’ also gives notice in accordance with Part II of Schedule 1 of intention to sell the abandoned goods. Or fails to trace / communicate with the ‘Bailor’ with a view to give him notice. After taking reasonable steps and is reasonably sure that the ‘Bailor’ owns the abandoned goods, the ‘Bailee’ can sell the goods.
The ‘Bailee’ can’t give a notice of intention or sell abandoned goods (Part II) if there is a dispute about all or part of what they claim to be due to him in respect of the goods. This isn’t what some have written as referring to any monies the ‘Bailor’ tenant owes, i.e. outstanding rent.
Also, if the ‘Bailee’ claims any monies due in connection with those abandoned goods, the Notice period for sale / disposal shall be 3 months [Schedule 1, Part II section 6(3)].
Let’s look at what are the duties of a ‘Bailee’
At common law, a person may become a ‘Bailee’ by voluntarily and knowingly taking possession of goods belonging to another. A ‘Bailee’ has a wide range of duties. Including the duty to take reasonable care of the abandoned goods in the ‘Bailee”s possession.
Examples of this are where an item may be taken to a trades person, such as a jeweller, cobbler etc. They knowingly take temporary custody of the item and you’ll commonly notice conditions on receipts setting out time limits. Often 3 months before the disposal of an item [as at Sch 1, Part II section 6(3) above].
An Involuntary Bailee is a person who has, without their consent, found themselves in possession of goods belonging to another. Regarding rental property, this may arise where a tenant has abandoned goods at the property after ending the tenancy.
An Involuntary Bailee does not owe the same duties as a Bailee. They must not deliberately or recklessly damage or destroy the abandoned goods. Or try to facilitate return of the goods to the owner. Or persons delegated to receive them on their behalf.
Elvin & Powell Ltd v Plummer Roddis Ltd 1933
Shop passes on abandoned goods that a fraudulent purchaser orders. HELD: Shop is an involuntary ‘Bailee’ of goods that the fraudster orders. Shop not liable in damages to the true owner of the goods, because it did act reasonably.
This case went on to produce the classic statement of the liability of an Involuntary Bailee in the judgement of Justice Hawke. “An Involuntary Bailee has an obligation to do what was right and reasonable.”
Discussion about Duties of an Involuntary Bailee includes…
Houghland v R R Low 1962
A coach passenger had to transfer from a defective vehicle to another. At end of journey, she could not locate her bag.
HELD: The duty of care of a ‘Bailee’ is the standard one. The person in possession of the abandoned goods [passenger] proves loss / damage is not because of their own actions / fault. Where the defendant’s possession of the goods was unintentional and with no lack of care, detinue [now wrongful interference] will not lie.
LJ Ormrod said “It seems to me that to try to put a bailment into a watertight compartment. Such as gratuitous bailment on the one hand and bailment for reward on the other. This overlooks the fact that there might well be an infinite variety of cases which might come into one or the other category. The question we have to consider in a case of this kind (if it is necessary to consider negligence) is whether in the circumstances of this particular case a sufficient standard of care has been observed by the defendants or their servants”
Just as in the pre-contract receipts from jewellers etc that we mention above. Its good practice for a tenancy agreement to have a clause dealing with this eventuality. Most agreements do, either in terms of requiring the tenant to give up Vacant possession at the end of their tenancy. Legal occupation of the property. Or stating what will happen if goods are left.
Cumberland Consolidated Holdings Ltd v Ireland : CA 1946
A warehouse had been left with rubbish – bags of hard cement in its cellars, affecting the value of the property and precludes proper use of the cellar.
HELD: Vacant Possession NOT given. In terms of items left behind, just any physical impediment will not necessarily preclude vacant possession. “The impediment must substantially prevent or interfere with the enjoyment of the right of possession of a substantial part of the property”.
NYK Logistics (UK) v Ibrend Estates BV 2011
NYK serves notice to implement their break clause, but retains employees on the site for a few days afterwards clearing their possessions. Immediately before the break clause date, they sought permission for this ‘extension’ from the owner Ibrend Estates, although they did not receive any response.
HELD: that property had to be significantly empty of chattels and people for vacant possession to be given. They did quote the Cumberland case and the decision upheld on Appeal.
Tenancy agreement clauses
Eminent legal advice has been to tread carefully with regard to tenants’ abandoned goods to avoid claims for damages. We outline some recent cases that help with some guidance.
The requirement to have a pre-defined clause that deals with what should happen in the event of goods being left behind is good practice. However the unfair terms in tenancy agreements (see below) are overly prescriptive and not proportionate to allow landlords to deal with a few low value items of furniture. Where the loss of a week’s rent would far outweigh the value of items knowingly left behind by the tenant. Let alone retaining them in the property, effectively creating a month’s rental void.
Office of Fair Trading OFT365
Guidance on unfair terms in tenancy agreements September 2005
“This document issued by the Office of Fair Trading (OFT) has been withdrawn. This document did not take account of developments in case law, legislation, or practices since its original publication. It should not be relied on either as a statement of the law or Competition and Marketing Authority [ CMA ] policy.
Current CMA Guidance on unfair contract terms can be found at unfair contract terms: CMA37. Replacing all previous OFT / CMA guidance on unfair contract terms when the Consumer Rights Act came into force 01/10/2015. Other information on the CMA’s consumer powers can be found in Consumer protection enforcement Guidance CMA58.”
Previous Unfair Terms
The tenant must pay a minimum charge of £100 to remove furniture left behind.
Way of revising term
The landlord will give the tenant notice that he considers that items have not been taken. If the tenant then fails to collect the items promptly, they will be liable for all reasonable costs of disposal.
Goods belonging to the tenant
In the event that the tenant’s belongings are left in the property after the tenant has left it. Such belongings ae then ‘abandoned’ and the landlord may remove, sell or dispose of these without being liable to pay for any compensation. The tenant will be liable for all costs of removal and disposal. Or any other losses and these costs and losses may be taken out of any deposit.
Way of revising term
The tenant will be responsible for meeting all reasonable removal and/or storage charges when items are left in the premises. The landlord will remove and store them for a maximum of one month. The landlord will notify the tenant at the last known address. If no one choose to collect the items within one month, the landlord may dispose of the items and the tenant will be liable for the reasonable costs of disposal. The landlord may deduct costs from any sale proceeds or the deposit. And if there are any costs remaining they will remain the tenant’s liability.
In any event, as it states above, this has been withdrawn and replaced by CMA37
Now that the above prohibitive unfair term (to Landlords) are removed. We turn to look at the Consumer Marketing Authorities replacement guidance
In short (as CMA37 is some 144 pages), there is now black-list terms. Such as those that waiver serious illness or even death upon fault or claim against the supplier/business. And grey-list terms that could in some circumstances be unfair (still subject to determination by the courts of law of course). Suffice to say, the proposals for dealing with abandoned goods via TIGA are not at variance. In fact, the Unfair enforcement powers [para 5.32 below] actually provide for how this should be dealt with.
The fairness test – section 62 2.10
A term is unfair ‘if, contrary to the requirement of good faith: it causes a significant imbalance in the parties rights and obligations under the contract to the detriment of the consumer.’
The fairness test thus includes the following main elements: significant imbalance to the detriment of the consumer and good faith. It must, however, we emphasise that the overall requirement is a unitary one – the question is whether a term is unfair. The elements of the test are capable of overlapping with each other in their application to any particular set of relevant facts. A rigid approach to assessing fairness, involving an artificial exercise broken into separate parts, is not appropriate.’
We would suggest that landlords rely on the ‘fairness test and good faith’. In the actions they carry out by inserting a clause in the Tenancy agreement. And promptly using the TIGA Notice within the timescale.
Fairness to both sides is the contractual agreement [AST]. That stipulates the landlord offers the use of the property between the agreed dates for the agreed amount. Outside of these dates the property owner has to rely on other tenancies. These other tenancies help fund the mortgage and financial burdens of a landlord.
There is no detriment to the consumer. Its common practice to pay for what you use. Try leaving luggage in a hotel whilst you go away on holiday. Or asking to park your car there without charge. The landlord’s circumstances are no different.
As for ‘good faith’ – both parties expect each other to abide by the terms of the agreement, ‘end of’. The tenant signing to give vacant possession and cease using the property upon termination of the tenancy.
There is nothing in the tenancy clause (see later, after the case of Campbell v Redstone). Or the subsequent use of the TIGA notice that contravenes the guidance that replaces CMA37, in fact the contrary.
Consumers’ circumstances – how they behave in practice
‘2.25 Economic research has drawn attention to a number of factors that the CMA considers are potentially relevant to the assessment of fairness. One of these is that most consumers do not read standard written contracts thoroughly before making a purchase.
2.26 This finding cannot be considered surprising, and it is not clear how it would be practical or economically efficient for consumers generally always to read all the terms of all contracts into which they enter, given the number of transactions in which they are involved and other claims on their time. It remains important that terms should be transparent, since those who do read them should be properly informed. But lack of time and ability to do so is an important source of consumer vulnerability that unfair terms legislation seeks to address.’
How does a landlord address this concern?
As in fact his dealings with letting agents often reveal the same trait, ‘Where do I sign?’ without taking the time to read several pages of small text (we don’t advise this).
We recommend that landlords send a copy of the draft tenancy agreement (with no signature) to the tenant by email, receiving acknowledgement. When a tenant is met at commencement of the agreement to go through the inventory, ask ALL tenants to sign at the bottom of EVERY page of the AST. The landlord can ask that they initial the paragraph dealing with giving up vacant possession.
5.6.4 The CMA has no objection to terms which, for example, allow the trader to charge reasonably for dealing with problems which arise owing to the consumer’s fault (but see paragraph 6 of the grey list at paragraphs 5.14.1 to 5.14.10 on the need to avoid imposing any unfair financial sanction – none of which impact on abandoned goods, especially where there isn’t a claim for any charges).
Unfair Enforcement Powers
5.32.5 The law [Torts (Interference with Goods) Act 1977] makes provision in detail as to how to normally treat such goods. A contract need not reflect these rules in detail, providing it does not override or contradict them. These terms are unlikely to be seen as fair, if they indicate that abandoned goods may be sold immediately. Or without adequate notice of the date and place of the sale. Particularly if they exclude the duties to obtain the best price and to refund any surplus. ‘
(Importantly, note the omission of a time, such as a month in the previous OFT365 guidance repealed by CMA37 on 1st October 2015)
Dealing with some recent cases
Da Rocha-Afodu v Mortgage Express Ltd, 2014
Concerning disposal of tenants ‘chattels’ after tenancy.
Da Rocha had a tenancy of a dwelling and fell into arrears. The mortgagee sought Possession. After several suspended possession orders, on 4/9/2006 Da Rocha was served with eviction notice and a letter accompanying, warning him to ‘leave the property with all your belongings before this date and time’. 9/9/2006
There were several subsequent visits by the tenant to remove ‘some’ of his possession well after this time and subsequent warning notices.
On a fourth visit some two months later, the tenant found that the mortgagee’s contractors did remove and dispose of all his possessions. The claim for value of the abandoned goods was £800,000! Although with evidence and sceptically received by the judges.
The Court of Appeal judges held that the tenant had an obligation to deliver up vacant possession on execution of the warrant.
They held (re-affirming) that the duties of an involuntary bailee was to do what was right and reasonable.
The claimant did contest that the mortgagee did breach the terms and conditions of the mortgage agreement. Section 9 which stated that steps would not be taken for a period of 7 days. The period running from the date notice was given to the mortgagors at their new address or, if no such address was given, 7 days after they left the property.
The Judge held that as no one did provide a new address for correspondence, Mortgage Express were NOT liable for breach of the mortgage conditions. Its worth repeating those conditions verbatum here:
Mortgage conditions Section 9
“The following will apply if we take possession of the property:
➀ If you have left any goods or animals at the property, we may take the following steps on your behalf and at your expense. Firstly, we may remove and store the abandoned goods and animals.
➁ ‘Then’ (this word was deliberated as having preferably been drafted as, ‘ OR’ – but did not impact the outcome).
➂ We may either dispose of them or if we know that they do not belong to you, return them to their owner.
➃ We will only take the steps mentioned in the previous paragraph if you have not removed the abandoned goods or animals:
– within 7 days after we have written to you at your new address asking you to remove them, or
– if you have not given us your new address, within 7 days after you left the property.
➄ Nothing in the first paragraph of this condition gives us any charge over any abandoned goods or animals left at the property. For example, we cannot keep the income from the sale of any goods or animals.”
The tenant’s appeal was dismissed.
Another Mortgage re-possession later that year
Campbell v Redstone Mortgages Ltd, 2014
This is a £500,000 mortgage that after many suspended possession orders since 2007 and part repayments, is eventually granted in 2014.
The mortgage issue agreement contains clause 6.1, 6.2 ‘Your Furniture and Personal Possessions’
“6.1 If we [i.e. Redstone] or a receiver take possession of the property, you [i.e. Miss Campbell] must, on Notice, remove all of your furniture and belongings. If you have not done so within 7 days of the Notice, we may as your agents remove, store or sell any items left behind.
6.2 Neither we nor the receiver will be responsible for any resulting loss or damage to your possessions. You must reimburse us for all our expenses of dealing with your furniture and goods. If we sell any of them we will pay you what’s left after deduction of those expenses…”
Evidence was also given that estate agents acting for the Mortgagee also chose to display similar notices at the property, pursuant to T.I.G.A 1977.
There were protests, demonstrations, writs to prevent mortgagee from continuing to remove abandoned goods, refusal of permissions to appeal, High Court Enforcement bailiffs, etc.
A number of visits to the property were made by tenants after the warrant for possession to remove items but they hardly did retrieve much. This did frustrate the re-possession, including barricading themselves inside. Eventually after more notices and several opportunities to remove abandoned goods, contractors acting for the mortgagee remove about a dozen van full of items which they dispose of.
There was a dismissal of a subsequent claim for the mortgagees to deposit £1 million on account to the court pending a trial for damages.
A warning tale about evidencing possessions
Diaz v Karim 2017 – Trespass to Goods
Mr Diaz was a law student renting a room when his Landlord chose to evict him and consequently chose to remove his possessions. A separate trial on that matter was ongoing and involves a claim for damages of £1 million(!) claiming that amongst the removal of possessions from Mr Diaz’s letting were: various I.T equipment, 3 emerald gemstones value £250k, a 1487 rare book with a value of £110k and a 1383 bible he paid £15k but had a valuation of £1.65 million! The Landlord was totally in denial about taking any possessions. There were no witnesses in attendance at court.
Mr Diaz was on Jobseekers Allowance. There were details of his purchase and ownership of the items in question at length in court. The judge found his account wholly incredible, awarding a nominal £5,000 for possessions that could be reliably inferred.
What’s to learn from these cases
Starting with the selection of tenants, thorough referencing and obtaining various contact and next of kin details. (see Referencing Tenants)
Including a clause in the tenancy agreement, further to the requirement of vacant possession, as to action taken in conjunction with TIGA in the event of any goods left at the property. A landlord may wish to use a clause similar to the mortgagees in the two cases above. Whilst remaining mindful of the clause not conflicting with TIGA or the CMA.
What are the circumstances of the tenancy ending?
Did the tenant notify their intention to leave and end their tenancy? If so, this should ideally be in are recordable form (at the very least, text message).
Hello? Anybody there?
Do you find that there isn’t any communication from the tenant about ending their tenancy and do you believe that the tenant is abandoning a property? If so, be very wary of moving any tenant possessions until either you comply with the Abandonment process of the Housing and Planning Act 2016, Sec 57-63. Or else you obtain a court order for Possession and the bailiffs facilitate Possession.
We look at when there hasn’t been any communication about ending a tenancy. A landlord should be very wary about their grounds for even entering the property. This should only be in an emergency or to secure the premises. In these circumstances, enter with a witness over 18 years of age and ideally, independent.
No contact might not mean no tenant
In cases where there hasn’t been indication of surrendering the tenancy. Be mindful that any goods remaining might actually be evidence of a tenants continuing occupation or intention to return.
On such occasions, the alternative contact details for a tenant can facilitate a response confirming their intentions. Helpfully pointing out their financially liability (and that of a guarantor, if there is one) continues until they’ve given acceptable notice of their surrender.
What Should I Do?
Take Photographs of the property, that includes what is, and isn’t present!
When Tenants indicate they are leaving, a check-out inspection shortly before their departure, and afterwards confirms ‘vacant possession’. Without damage deductions claims, deal with the deposit with 10 working days of the end of the tenancy.
For example, let’s say a tenant has left some rubbish. Take photographs and brief description of the refuse, so you have evidence it was rubbish if there’s a subsequent claim. There may be a partial deposit claim for this which your evidence will help secure. If you are feel confident you can prove its rubbish, you can dispose of it.
A Landlord needs to record any other abandoned goods on an inventory and list them on the schedule of items sent with the TIGA Notice.
‘Right and Reasonable’ explained
Persevering through the legislation, there now comes the practical aspects of dealing with whatever abandoned goods remain. A landlord may have to demonstrate he is doing what is “right and reasonable”. Justice Hawke, Elvin & Powell Ltd v Plummer Roddis Ltd, 1933.
Held as the liability of an Involuntary ‘Bailee’ and is referred to since that time.
The origin of the legal definition of a ‘reasonable man’ is said in legal dictionaries to emanate from a 1872 Civil trial of Titchbourne v Lushington. (The later) Lord Bowen describes ‘reasonable’ as what the man on the Clapham omnibus would regard as such. A description of such a person [passenger] was a ‘reasonably intelligent and impartial person not familiar with legal esoterica [complexities] in contemporary parlance. It is still in use as ‘the man in the street’ (and adding the Museum photo of Nixey’s horse-drawn bus).
Attending a property after a Tenant’s prior notice has been given about the vacation of tenants.
For this purpose, we are assuming no damage deposit deductions. Other than what might arise from expenses of dealing with property restoration to vacant possession.
We find the following items (as an example) in the list by our independent witness below, including photographs, in situ.
Items left by tenant
- Sofa, 2 seater smelling a little musty and evidence of staining. In well-used condition. No manufacturer details or firelabel
- Double-Wardrobe in front bedroom, empty apart from one dirty tie lying on the floor. Wardrobe is a chip-board laminate construction, loose hinge and ill-fitting door.
- Electric 4 ring cooker, Creda manufacturer. In dirty condition with defective oven door that does not fully close properly. Still connected, only 2 rings operating.
- Picture on wall in front lounge of country forest setting, signed by artist who’s name is unreadable.
- Dark Wooden side-board cabinet, 800mm wide, 300 deep and 650 high. Appears solid wood, no manufacturer details visible. Drawers contain some family photographs some of which the landlord believes feature the last tenant.
An Example of a Landlord Inspection
From the last landlord inspection visit on (date), there were numerous items of tenants furniture that they chosen to remove. Such as 3 seater settee, flat-screen television, fridge and beds from both bedrooms.
The in-built wardrobe in rear main bedroom is empty of clothing apart from a dirty shirt lying messily on the bottom.
What does the above inventory say – infer? That the tenant has taken a substantial amount of their possessions [what they want?]. And left behind a small number of low value, dirty and partly defective items.
Note a schedule of the items
Immediately note a schedule of the items. Just their underlined broad description, not including condition, will be entering onto the TIGA Notice. Then sent to any next of kin or forwarding address that landlord has been supplied.
If there isn’t an alternative address, TIGA Notice to be posted ‘Recorded Delivery’ to the tenant at the property address. Reason: Recorded delivery, because that’s the method stated in the TIGA legislation, and to the tenanted address, that you believe they’ve left (and probably won’t receive), in case the tenant has set up a mail forwarding arrangement with the Post Office. Also, you’ll have the recorded delivery receipt to show your actions.
Tenant in receipt of Housing Benefit?
If the last tenant was in receipt of housing benefit, contact the Local Authority Housing department, ask to speak with their Tenant Relations Officer (if they have a designated TRO) or someone from that department. Your enquiry is in case the tenant may have approached them to seek assistance with alternative accommodation.
If that is the case, don’t expect any data such as current address to be disclosed. However you are informing a third party who has contact with the last tenant, that you are trying to facilitate the return of their abandoned goods (perhaps even offering to forward the TIGA Notice, if they’ll pass that on). If this line of enquiry is fruitless, all it costs you is a telephone call and a follow up email. Taking details of the person you spoke with as a summary email of your conversation for your evidence of… ‘doing what is right and reasonable.’)
The landlord will be well advised to note details of the provision (or lack of) second-hand furniture outlets in that nearest town. As its not going to be cost effective, given the items value to travel any further.
Selling the confirmed Abandoned Goods
Apart from antique dealers, second-hand furniture re-sellers are few and far between. Try an internet search for the town nearest one of your rental properties. Most of the results will be charity shops that take in reasonable quality re-saleable furniture donated for them to sell in middle to upper double-figures to raise money for their (worthy) cause.
If an internet search reveals one seller, you could contact them and offer to send a decent photograph of an item that could be saleable. In the inventory list above, that might possibly be only the solid wooden side-board.
The furniture shop, may decline your offer to even receive the photograph, as they ‘only deal in antique pine’, note their name and time of your call. Perhaps you can show, send a photograph by email to one of the charity shops? If they don’t want to take it, that really speaks volumes. Take a screenshot of your internet search (it’ll be time and dated).
Have you done everything that is reasonable?
The stated cases of Da Rocha, and Campbell would suggest so (and there was far more at stake there). 7 days notice was enough in those cases, although subsequent notices and a further period was given prior to disposal. These cases were prior to the CMA37 when the previous OFT365’s ‘revised term for Goods belonging to the tenant’ suggested the landlord’s terms were to retain for up to a month – weren’t even raised let alone challenged.
In a tenancy where low value items are involved, even the Consumer Marketing Authority is now of improved assistance to landlords. With the Fairness Test relying on the ‘significant imbalance, detriment to the consumer and good faith.’
The value of uncollected goods
Establish an independent view of the value of abandoned goods (would your independent witness have the items in their home?) and how does that stack-up against the cost to the landlord of 7 days [ TIGA Notice period ] of rent – ‘significant imbalance’ – in landlord’s favour?
Detriment to the customer – the tenant has ‘chosen what items to take’ and left the remainder, knowing the terms of their tenancy, i.e. Vacant Possession. If the tenant was, acting in good faith and experiencing short-term difficulties in removing large items, the landlord’s permission could have been sought.
7 days later, if there’s been no response to the TIGA Notice, landlord considers options.
If there’s an outbuilding where the solid wooden cupboard and picture can be stored, that may be an option or offered to a charity shop.
Valuation and family photos
Should this be the case, it may be useful to see what prices they’re asking for that or other similar second-hand pieces of furniture. If not, remove the family photographs and the wall picture for a further short period.
Possibly another 14 days, because these items are portable and won’t be difficult to temporarily retain. By doing this, it adds to the ‘Right and Reasonable’ evidence (protects against accusations from tenant, e.g. “My landlord skipped the lot!”).
The remainder of the items can be disposed of to the Civic amenity recycling centre.
All landlord actions documented and recorded that show reasonable conduct.
Actions against Landlords
The actions against Landlords raised at court are mainly outright illegal eviction where a tenant’s possessions have been removed and dumped / outside and locks changed. In which case, there’s a lot more to worry about that a claim for their possessions). Or, inflation of claims such as those outlined in the cases of Da Rocha and Diaz above.
Instances where tenants have left low value bulky items and have brought claims against a Landlord are practically unknown (if someone does know of an unreported case, please let us know).
This is primarily because there is no legal aid available for Trespass or damage to abandoned goods. You will have to assure a solicitor that there is a significant sum at stake and prospect of success. Before taking a conditional fee arrangement (No-win, no-fee). The Tenant is unlikely to have the funds to initiate a legal action.
How a landlord can show what they’ve done what is ‘right and reasonable’ can be influenced largely by acting with the knowledge and suggestions of this paper – your feedback is welcome.
Stated cases, legislation [ TIGA ] and now the CMA align, so the only remaining anomaly is the How to Rent Guide! See ‘Clear Up‘ below.
Landlords may wish to forward the below email, or compose one themselves, to: firstname.lastname@example.org
From: ‘a Landlord’s email address’
Subject: F.A.O. – Authors / Responsible for How to Rent Guide
I’d like to draw attention to an error, or misleading statement in the How to Rent Guide:
“Remove all your possessions, clean the house, take meter readings, return all the keys and give a forwarding address. The landlord is entitled to dispose of possessions left in the property after, typically, 14 days.”
The CMA OFT365 previously suggests that this ‘period where a landlord had to give a tenant [ Bailor, as they’re known in the Tort’s (Interference with Goods) Act 1977 ] notice to remove any abandoned goods, was up to 28 days.
This has been withdrawn (stated as did not take account of developments in case law, legislation, or practices since its original publication. It should not be relied on either as a statement of the law or CMA policy) and CMA 37, para 5.32.5 now deals with the issue as the landlord having to be fair and abide by the Torts Act, as quoted above.
The legal position in accordance with the Torts legislation, is that the landlord must give the tenant a notice complying with Section 12 (1) and (3) of Intention to Collect and sell the abandoned goods.
Da Rocha-Afodu v Mortgage Express Ltd, 2014 and Campbell v Redstone Mortgages Ltd 2014
Both these served Notices giving 7 days for tenants to remove all their goods and were Upheld by the Appeal courts.
The CMA37 refers to The Fairness Test, and there being ‘No significant imbalance between the parties to a contract, No detriment to the consumer and good faith’.
Where the tenancy agreement / legal contract agreed between both parties to which their equally bound, provides for the Tenant paying rent until the end of their tenancy, whereupon they agree to give up vacant possession – there is NO imbalance, let alone significant imbalance.
Landlords have to move the property on to the many waiting tenants for accommodation, whilst the landlord still has to service the financial commitments.
As for ‘Good Faith’ – the expectation and practice of good faith, is both parties keeping to what they’ve agreed and committed to.
In cases where tenants have left some used bulky furniture behind, AFTER they have chosen to remove the rest of their belongings, cannot be fair to a Landlord where the value of the items is next to worthless. The Tenant has had every opportunity to remove them with the rest of their possessions and their value is far out-weighed by 7 days loss of rent.
Case law above refers back to and has upheld the duties of an Involuntary Bailee (landlord) as having to do no more than what was ‘right and reasonable’.
Removal of goods
Where a tenant has ‘chosen’ not to remove goods, eminent case law above did decide that a 7 day Tort compliant notice is sufficient (even where the property was of substantial value).
Leaflets that purport to suggest otherwise than the law are not helpful to tenants, or landlords and will only serve to keep more property unavailable for accommodation for longer than is necessary.
There is also case law on goods left in a property after a tenancy ends, as constituting the tenant NOT having given up Vacant Possession, and thereby, is still liable for rent:
Cumberland Consolidated Holdings Ltd v Ireland 1946
and more recently,
Ibrend Estates BV v NYK (UK) Logistics Ltd 2011
Can I suggest the relevant part of the How to Rent guidance is updated to reflect ‘Fairness to ALL parties’, and of course, legally compliant.


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More areas can be controlled and adjusted with additional Smart Radiator Thermostats. Using the Smart Radiator Thermostat Kit as a basis, the system can be extended to include additional thermostats, so more rooms and zones can be connected to the basic system. This gives users a more comprehensive picture of the heating processes.
All payment options and shipping as economy package are free of charge.


Chinese authorities looking into alleged antitrust violations by Microsoft have given the company twenty days to "make a written explanation" to questions and concerns raised by investigators.
...of Microsoft highs and lows, Windows 10 wonders, and Nintendo's big Switch
Unboxing the Lenovo Moto Z reveals some unexpected surprises
ZTE Nubia Z11 Max: Amazing hardware marred by a lacking user experience
nubia z11 max
Lenovo Yoga Book with Android unboxing and first impressions
lenovo yoga book
It's finally here: HP Elite x3 unboxing and first impressions
It turns out that it's actually cheaper to fly from Australia to the United States, purchase Adobe CS6, then fly back, than it is to pick up a copy of the software in a local Australian store
Until now, they have been avoiding the politcians, but the Australian government has demanded that Adobe, Apple and Microsoft all attend hearings around the IT pricing inquiry.
Ambitious plans for an online video on demand service offering more than 10,000 hours of classic TV shows from the BBC, ITV and Channel 4 were hit yesterday by a decision to refer them to...
European Commission regulators have taken over a German antitrust investigation into allegations that Intel put pressure on a major electronics retailer to forgo using processors from competitor AMD. Germany's antitrust agency, Bundeskartellamt, received a complaint...


text:
Kaizer Chiefs coach Ernst Middendorp has not taken kindly to the constant speculation over the future of star striker Khama Billiat.
Billiat has been the subject of widespread transfer speculation in recent weeks, with interest in his services both from abroad and within the PSL.
The Zimbabwean attacker’s absence against Highlands Park over the weekend, though Chiefs explained it as an injury precaution, further suggested that something could be going on behind the scenes after Pitso Mosimane also added fuel to the fire.
However, despite an earlier assertion that no one would be leaving the club at this late stage of the transfer window, Middendorp appeared irked upon again being questioned regarding the player’s future, as he directed media towards the club’s management.
“I don’t want to be part of this speculation. You go there in this moment and ask the management, who are aware about what his [Billiat] contract situation is,” said Middendorp.
“I think the player knows his contract situation, and for me there’s nothing to discuss.”
While the 28-year-old is undoubtedly an influential figure on his day, the German tactician further refused to discuss whether he – along with other key members in the squad – would be in the team for this weekend’s test against Black Leopards in Durban.
“Everybody is available for Kaizer Chiefs. Nkosi Ngcobo, Happy Mashiane, Khama Billiat, Rama Mphahlele, Itu Khune; everybody is available for Kaizer Chiefs,” he insisted.
“As for how far they are in the training process, I think that is something that we discuss internally and not in public.”

domain: news


text:
FRIDAY MAY 1, 2015 ~ 5-9PM @ UNITY PLAZA
The Third Annual TEE OFF DOWNTOWN is moving from The Shipyards to Unity Plaza! The event kicks off PLAYERS CHAMPIONSHIP week with a bang with live music featuring Edwin McCain, as well as cash bars, food trucks, and games. The event is free to the public. What better way to TEE OFF the weekend, than Happy Hour at Unity Plaza!
Concert with Edwin McCain

domain: entertainment


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Prepare to be smitten with this gorgeous embroidered and beaded ball gown with illusion slight cap sleeves, a wide V-neckline, an illusion boned bodice, an illusion wide V-back, and a gathered voluminous skirt with on-trend pockets and a sweep train.
Delivery time: 14-16 weeks to arrive into our store. Stock is available on some colors/sizes. If you need a dress on short notice, please contact us to check stock. Allow 1-2 weeks for shipping.
All sales are final so please refer to the measurements on the size chart.

domain: design


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"Dreamer is a wonderfully imaginative novella for those who love light magic and rock music. Dream Traveling is such a captivating magic that it had me on the edge of my seat the entire time. My dreams are heavily influenced by real-life (especially horror movies) and so seeing Vera be tormented by her dreams like this poured right into my subconscious. Highly imaginative and smart, this novella is sure to pull you in."
Multi Mind, author
Vera has quite unusual dreams. Whatever she dreams, affects her in real life. All is fine until one day, she sees something she thought she could handle – instead, she’s plagued with a reoccurring nightmare, haunted and tracked by The Hunter. Now she worries she may never wake up again.

domain: literature


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Join the game, you never spawn in or anything. Check the dev console client view and you get this stack trace. Starting happening today.
UPDATE: The error is unrelated to the broken game. The game broke because LocalScripts are no longer copied from StarterGui into PlayerGui. Writing a simple patch completely fixed the problem:
local contents = game.StarterGui:GetChildren() for i, v in next, contents do v.Parent = nil end game.Players.PlayerAdded:Connect(function(player) for i, v in next, contents do v:Clone().Parent = player:WaitForChild'PlayerGui' end end)

domain: game


text:
Our programme of engagement was created in close consultation with the In-house Lawyers Division committee, to ensure it is relevant and timely.
Committee members are scheduled to meet up to four times a year to discuss the key issues facing the in-house legal community. The committee advises how the Law Society can best support its members who work as in-house lawyers.
The In-house Lawyers Division committee is chaired by Sapna Bedi FitzGerald, legal services director and company secretary at LSL Property Services plc. Stephen O’Brien, lawyer from the Employment Group at the Government Legal Department is the vice-chair.
The Law Society thanks all of the committee members, whose details are included below, for their time, commitment and contribution.
|Clare Belcher||Travelex Limited||Head of Legal, Global Business Development & EMEIA region|
|Peter Clark||Oxfordshire County Council||County Solicitor and Monitoring Officer|
|Sue Dauncey||Avon and Somerset Constabulary||Director of Legal Services and General Counsel|
|Sapna Bedi FitzGerald||LSL Property Services plc||General Counsel and Company Secretary (chair)|
|Trevor Goodman||Legg Mason||Head of Legal EMEA|
|Dennis Hall||Gateshead Council||Commercial Manager and Solicitor|
|Donna Harris||Aviva plc||General Counsel, Real Estate|
|Matthew Heath||Fidelity Worldwide Investment||Head of UK Legal Services|
|Stephen O’Brien||Government Lgeal Departments||Lawyer, Employment Group (vice-chair)|
|Emily O’Neill||Spectris||IP and Litigation Counsel|
|Dominic Pickersgill||Institute of Engineering and Technology||General Counsel|
|Kavita Savani||Financial Ombudsman Service||Legal Counsel|
|Helen Shay||University of York||In-house Solicitor|
|Richard Somerville||Electricity North West||Head of Legal|

domain: law


text:
19 Mar 2019
Lizzie*, a young person in our care, was recently selected to compete in the YMCA Australian Skateboarding League National Finals held in Melbourne on 8 and 9 March. This was Lizzie’s first invitation to compete on a National level, so she was extremely excited to hear the news. Lizzie is a highly skilled skateboarder who has received multiple medals for her efforts in local competitions. Lizzie, accompanied by her residential care worker, travelled down to Melbourne last weekend for the competition, where she placed in the top 10.
Mercy Community (MC) is incredibly proud of Lizzie for her efforts last week, and the whole team looks forward to seeing her thrive and succeed in her future skateboarding competitions. Lizzie’s team was thrilled to be able to support her throughout the process of the National Finals, as MC’s main purpose is to support the young people in our care to live out the life of their dreams.
*Name and image has been changed to protect the identity of the young perso


text:
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Vintage Gold Compass Earrings: Find Your Way with Style
Introducing our Vintage Gold Compass Earrings, the perfect accessory for passionate sea lovers with an eye for style. Crafted with precision and infused with a touch of nostalgia, these earrings are a delightful addition to our Compass Earrings collection. Designed to capture the essence of the sea, our nautical-inspired jewelry selection combines elegance and craftsmanship.
Features of Vintage Gold Compass Earrings based on Product Content
- Style: Embrace the timeless appeal of vintage fashion with these stunning compass earrings.
- Shape\pattern: The perfectly round shape symbolizes harmony and balance, reflecting your love for the sea.
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When you wear our Vintage Gold Compass Earrings, you carry a piece of the sea with you wherever you go. These earrings not only enhance your personal style but also serve as a reminder of your deep connection to the ocean. As a passionate sea lover, you deserve jewelry that reflects your spirit and passion.
With their vintage charm and elegant design, these earrings are a versatile accessory that can be worn for any occasion. Whether you're attending a beach wedding or simply enjoying a day out by the ocean, our Vintage Gold Compass Earrings will complete your look with a touch of sophistication.
Add these earrings to your Compass Jewelry or Nautical Earrings collection and let your love for the sea shine through. Perfect as a gift for a loved one or as a treat for yourself, these earrings are a must-have for every passionate sea lover.
Indulge in the captivating allure of the Vintage Gold Compass Earrings, and embark on a style journey that celebrates your deep love for the sea. Shop now and let these earrings guide you towards your own unique sense of fashion and adventure.
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text:
First published in The Times, Monday July 16 2017
There is always an element of suspense for audiences to any production of Measure for Measure – even for those who have seen Shakespeare’s most problematic play many times. How will the director and company reconcile the pessimistic depiction of corrupted power, sexuality and relationships with the play’s supposedly comedic elements, including the final flurry of marriages, two of which are meted out as punishments?
Continue reading “Review: Measure for Measure – Botanic Gardens, Glasgow”
First published in The Times, Friday July 22 2016
Staging outdoor theatre in Scotland is a risky business. Just ask Gordon Barr, the artistic director of Bard in the Botanics, who has been anxiously watching the skies above Glasgow’s west end every summer for the past 15 years.
The weather gods were smiling on the opening performance of his new production of the Scottish Play, however. As the city sizzled in a heat wave, the crowd gathered in extraordinary numbers on the grassy embankment at the back of the glasshouses in the Botanic Gardens. For once, the extra clothes, the blankets and sleeping bags, proved surplus to requirements.
Continue reading “Review: Macbeth – Botanic Gardens, Glasgow”
First published in The Times, Thursday June 30 2016
While cross-dressing is central to the plot and resolution of a number of Shakespeare’s comedies, Twelfth Night occupies its own league as a comment on gender construction and elastic sexuality. The female protagonist spends most of the play dressed as a pageboy, inadvertently stirring the passions of a woman who has forsworn all male suitors while simultaneously harbouring a secret love for a nobleman. Talk about progressive.
Continue reading “Review: Twelfth Night – Botanic Gardens, Glasgow”
First published in The Times, Tuesday June 30 2015
Love’s Labour’s Lost is one of Shakespeare’s earliest comedies and its dizzying verbosity and baggy middle section does suggest a playwright still finding his fleet feet. That said, in the play’s depiction of a group of young lovers overcoming social hurdles, misunderstandings and mistaken identity to achieve a happy ending, one does find an early template, not only for the Bard’s great comedies, but for the enduring Hollywood screwball farce.
Continue reading “Review: Love’s Labour’s Lost – Botanic Gardens, Glasgow”

domain: artistic


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This is a quick, delicious, guilt free dessert that you could make the previous night and keep in the refrigerator to soak in all the lovely flavours. Children love it and so do adults. We tried it out on a group of people a few weeks ago and it was walloped in 10 minutes flat. Maybe you'd like to try it too.
1 cup thick curds; honey to taste; 2 tablespoon oats; fresh fruits of your choice- I used two kinds of melon, pomegranates, grapes; 1 tsp chia seeds.
Beat the curds and honey till smooth. Using a ball tool, scoop out the melon flesh into attractive rounds. Peel the pomegranate and keep ready with other ingredients in a dish.
Take a transparent disposable plastic glass and put 1 dsp of oats at the bottom of the glass. Pour 1/3 cup curds and honey mixture over. Arrange a layer each of melon, grapes and pomegranate seeds on top. Pour 1/3 cup curds over. Scatter the chia seeds on the curds. Add the remaining oats and repeat the layers ensuring the melon and pomegranate are on top. Close and keep overnight in the refrigerator. Next day, enjoy this delectable desert whenever you feel like it.

domain: food


They are pneumatic devices that allow you to reduce the air pressure in a system. The main purpose of these devices is to ensure that your equipment or system gets a smooth and desired air pressure to perform the operations effectively. Generally they control the pressure in the air lines that are used in pneumatic systems and other machines. By using the digital air pressure regulator you can remove the fluctuations available in the input pressure. This is the main and the vital characteristic of the pressure regulators.
What is an Electronic Air Pressure Regulator?
Pressure regulators are the valves that use the feedback feature to control the pressure in your system. They are used in the pneumatic and hydraulic systems. In a system where pressure flows from one place to the other, an electronic pressure regulator adjusts the pressure according to the desired values set by the user. When buying the one for you, keep in mind that you should consider the fluctuations in the inlet pressure and the desired output pressure. It is necessary to determine the fluctuations of the flow rate to ensure that the regulator will not fail. In this way, you can determine which regulator will be a good fit for your system.
To Reduce the Pressure:
The main purpose of a pressure regulator is to reduce the high pressure and maintain the required value of the pressure in the system to reduce the chances of potential hazards. Because, the presence of a high pressure in your pipes and the system can burst the system or the pipes. When they’ll have to bear high pressure regularly then they will become weak and will not be able to provide the expected outcome. And at the end it can become the reason for a dangerous incident. With the help of an electronic air pressure regulator, you can keep your workers and the system safe. As it reduces the pressure and maintains a constant pressure according to the need.
When the pressure increases than the set limit, it informs the controller so that it can be checked for any kind of repairs and replacement. Resultantly, the age of your systems or equipment also increases.
For Adjustment of pressure:
Digital pressure regulators can effectively adjust the pressure in a system. In manual regulators there were nobs or screws that were rotated to increase or decrease the pressure and it was not easy to maintain a constant state. Many people were used to being involved in the process. But now with the help of an electronic air pressure regulator you can easily do that by just sending the electrical signal while sitting on your seat.
A pressure regulator that is controlled electronically allows you to handle the pressure in the system by increasing or decreasing the size of the orifice. While using an electronic air regulator, you should keep in mind that if the orifice will be open too much then there will be chances that the fluctuations will occur in the pressure. So you must take care of that while adjusting the pressure.
To Obtain Accuracy:
In the old times, it was very difficult to obtain the accurate pressure according to the need of the system with the help of mechanical regulators. Nowadays, one can conveniently reduce the high pressure and maintain a constant pressure by using a proportional pressure regulator. Further, they enable the users to electronically handle the pressure. The accuracy is measured by the amount of droop in the flow rate. When the flow rate increases then the pressure decreases and is called droop. Therefore, the regulators having high droops are more expensive than the general regulators.
Three Useful Types of Electronic Air Pressure Regulator:
A pressure regulator allows the users to limit the pressure as per the requirement of the systems and is usually defined by the controller. There are three different types of these pressure regulators. They are available in various sizes, shapes and pressure ranges to fulfill the needs of all the users. The accuracy and stability can be obtained by using the right type and design of the regulator.
Here we have three main types:
In this type of electronic air pressure regulator solenoid valves are used. With the help of these valves they get the pressure input and exhaust it into the atmosphere. In the downstream section the pressure is controlled by letting in and out the molecules of gases or air. The feedback that is generated from the downstream pressure sensor is measured and processed by the control algorithm. It opens and closes the solenoid valves to maintain the set limit of pressure in the system. To have the precise pressure many inlet and outlet valves can be used. In this type of the regulator a high precise pressure can be obtained with a minimum effort. The life of these valves is affected by the fluctuations of the inlet pressure.
The examples of these digital pressure regulators are Mensor CPC4000 and CPC6050. They are used to having years of operations with the minimum chance of failure. Nowadays, solenoid valves are used in many applications, preferably in control systems where precision is the first priority.
The filer proportional pressure regulators are vital to keep your system and the regulator safe from the dirt particles. These particles can block the regulator and the flow of the pressure. That’s why they are necessary to be used to keep the air line clean while reducing the pressure to the set point. With the help of these electronic air pressure regulators you can ensure the safety of your expensive lab equipment, and valve positioners. In these regulators the air passes through the sintered polyethylene filters having the size range from 5 to 40 microns to filter out the moisture and the dirt particles.
All of the things that are extracted from the supply are stored in a drip. You can manually clean the drip or it can be done automatically with the flowing fluid. The sensitivity of all of these electronic air regulators is equal to 1 and are available in aluminium or stainless steel. Moreover, they are categorized into two types: relieving or non-relieving.
General purpose Regulators:
When the cost is the first priority then you should go for a general purpose electronic air pressure regulator. Mostly, they are used in OEM applications. They are sensitive to 1/8 water columns. Meanwhile, they are not created to inhale a large amount of air so you will see less consumption of air while using them. Because of this characteristic, they are mostly used in the fluid power industry and in control instruments. These electronic pressure regulators are economical and are good for the individual airline that needs a unit with a greater flow.
Various pressure regulators are available in the market but using the electronic air pressure regulator one can control the pressure effortlessly. The electronic air pressure regulators are classified according to the features and slight difference of working principle. So choose the one wisely that has the appropriate features to help you out in maintaining the constant pressure.


Yes, in a way they are. The efficiency of a wind turbine depends on a number of factors: the power in the wind is equal to (the density of the air) X (the diameter of the turbine blades squared) X (the velocity of the wind, cubed) X (a constant.) Therefore it seems that the way to get the most energy out of wind power is by placing a turbine in a spot with the densest air (sea level) and high wind velocities and increasing the size of the turbine blades. Scientists are currently hoping to do this in offshore wind farms and by using enormous turbine blades. The largest, and most energy generating wind turbine has a 7+ megawatt capacity. However, according to Betz’ law formulated way back in 1919, the most energy any wind turbine can generate is 59% of the power in the wind. If a turbine were to convert all the power in the wind into energy, then there would be no wind left on the other side.
We are always improving our designs for renewable energy.
These are my favorite, for their beauty as well as their efficiency.
“For many years, a fellow named Bil Becker has been hard at work developing hisAerotecture turbines. The turbines are elegant devices which incorporate bothSavonius and Darrieus styles into one turbine.”
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text: The influenza virus circulates yearly and causes global epidemics. results to the mom, the fetus, or the newborn after maternal influenza vaccination. We present the existing data on the performance and protection of influenza vaccination during being pregnant in avoiding disease in the youthful infant. evaluation of the South African trial, maternal vaccination was associated with a 57% (95% CI 7%, 81%) reduction in all-cause acute lower respiratory tract infection (LRTI) among infants younger than 3 months old. Notably, this observation was independent of identifying influenza virus among the hospitalized cases, suggesting that preventing influenza infection may prevent subsequent LRTI in young infants. The negative polymerase chain reaction (PCR) results for influenza infection among these LRTI hospitalized cases may be partly explained by inadequate sample or imperfect test sensitivity. At least in adults, it has been shown that serologic assays demonstrated higher seropositivity for influenza than molecular testing, suggesting higher exposure than when looking at PCR-confirmed illness only 64. It is also likely that exposure to the influenza virus initiated a causal chain of events leading to hospitalization for LRTI, even after virus shedding had ceased. Influenza virus infection could have increased the susceptibility to new bacterial nasopharyngeal acquisition, as well as increased the density of existing colonizing bacteria, with AR-C69931 cost disease from these bacteria manifesting only a few weeks after virus clearance 65C 67; this is supported by epidemiological studies during the influenza epidemics and animal challenge models that demonstrated that influenza virus infection can enhance the susceptibility to infection with bacteria 68, 69. Duration of protection The duration of passive protection in the infant conferred by vaccination during pregnancy Rabbit polyclonal to INPP5K depends on the levels of antibodies achieved by vaccination, which are contingent on the efficiency of AR-C69931 cost the transport across the placenta and how quickly the passively acquired antibodies wane. Half-lives of 42C50 days have been described in South Africa 53 and Bangladesh 49 for the different influenza-specific hemagglutinin antibodies in infants whose mothers received influenza vaccine during pregnancy. However, in HIV-uninfected women vaccinated during pregnancy, half-lives of the antibodies were about 100 days 53. The effect of the decay in antibodies in infants was evident from the highest vaccine efficacy observed during the first 8 weeks of life in the South African trial AR-C69931 cost (86% in infants younger than 8 weeks old versus 49% in infants younger than 6 months old) 70 and the first 4 months of life in Mali (68% in infants younger than 4 months old versus 33% in infants younger than 6 months old) 21. It’s been postulated that the primary mechanism of baby protection against laboratory-confirmed influenza infection provided by maternal vaccination is usually via the IgG antibodies that cross the placenta; however, the overall effect of protection is further confounded by the possible benefits of breastfeeding and reduced risk of exposure to the influenza virus from vaccinated mothers. Breastmilk and protection against influenza Besides the serum antibodies received via the placenta, protection might be provided by antibodies in the breastmilk of vaccinated mothers. This route of protection might be especially important for prematurely born neonates who had limited transplacental transfer of antibodies. However, immune responses in breastmilk after maternal vaccination have been less studied. In the trial in Bangladesh, breastmilk samples were obtained and specific IgA antibodies to H1N1 were significantly higher in IIV recipients than in mothers who received the pneumococcal vaccine for at least 6 months postpartum 71. In the same study, exclusive breastfeeding was associated with a decrease in the number of episodes of respiratory illness with fever in infants of mothers who received influenza vaccine during pregnancy. Influenza vaccine and AR-C69931 cost HIV-infected pregnant women Infants born to HIV-infected mothers, even if themselves not HIV infected (HIV exposed, uninfected infants), have an increased risk of hospitalization and death from respiratory virus-associated LRTI, including influenza virus 72, 73. In South Africa during 2011, a smaller immunogenicity trial was performed in 194 HIV-infected pregnant women. Women were randomly assigned to receive IIV or placebo, and their infants were followed for laboratory-confirmed influenza until 6 months of age 19. Before vaccination and 1 month post-vaccination, HIV-infected compared with HIV-uninfected pregnant women had lower levels of influenza-specific hemagglutinin antibodies and a decreased likelihood of seroconversion 53. The transplacental antibody transfer was similar in the HIV-infected and HIV-uninfected cohorts for two of the.

domain: medical


text:
Meet Our First Girl of Summer: Danika
STU global finds VYM
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text:
I am having a week of which mystery lovers everywhere dream. After weeks of moaning in a my book posts about the dearth of good books to read, I have for the last few days been in mystery lovers’ nirvana. The state of perfect happiness, when the literary planets align, and everything I read, listen to, or watch is great. Sigh.
I’m finally reading Tana French’s latest book, The Witch Elm (affliate link) I’ve been on the waiting list at the library for ages. This week I have had my nose deeply buried in that book. First on my i-pad and then in hard copy. I love Tana French’s work. Her Dublin Murder Squad series has been very, very good.
I liked The Wych Elm or The Witch Elm a lot right off the bat. Then, to be honest, I grew a bit impatient with the somewhat rambling structure. But I kept reading, was captivated again, became a bit impatient with Toby’s situation, persisted, and then finally became totally engrossed. But let me back up a bit.
The Wych Elm is the story of Toby Hennessy, his family, his friends, and his girlfriend as they navigate through some pretty traumatic events. Events that will eventually wreak chaos in their lives. Toby is handsome, bright, young, has a beautiful girlfriend, good mates, and a great job. He is a very lucky man. But at the beginning of the novel he doesn’t seem to understand how lucky he is. He doesn’t comprehend the depth of his privilege. As his friend Dec points out, he “hasn’t a clue” how charmed his life has been.
Then things go awry. Toby has a moral crisis at work, his apartment is burgled, he is attacked by the thieves, and left for dead. Toby doesn’t die, but the physical, emotional, and psychological damage is huge. He struggles to recover; he has physical limitations, and his nerves and his memory are shot. Then Toby and his girlfriend move into Toby’s grandparent’s house, to act as carers for his beloved uncle Hugh who is dying of brain cancer. And for a time, the peaceful routine they fall into, and being once again in the home where his father and uncles grew up, and where Toby and his cousins spent every summer as children, seems to be working. Until they find the skeleton. In the wych elm tree.
The Wych Elm is a “slow burn of a novel”, as Anna Carey says in her review in The Irish Times. As Toby, his family, and the police try to uncover how the skeleton came to be in the elm tree, things fall apart. The mystery of the skeleton is complicated by Toby’s attempts to piece together his past. Relationships become strained, and Toby begins to wonder how well he knows family members he’s “known” all his life. Who can he trust? Can he even trust himself? As Carey says in her review, “Toby is a particularly fascinating unreliable narrator.”
French plays with several themes in this novel: the idea of privilege, the effects of trauma, family dynamics, friendship, responsibility. But perhaps the most interesting theme that is explored is that of identity. Are we the person we think we are, or are we the person others see? I tell you folks, just thinking about that really messes with your head.
Now let’s take a moment to discuss wyches or witches, and which wych is which. As I read this book, I began to notice that the characters referred to the wych elm in the backyard. Huh. “So then why is the novel called The Witch Elm?” I wondered, “Where’s the witch come into it?” And when I did my research, I saw that in the UK the novel was published under the title The Wych Elm. I hate it when North American publishers change stuff like that. Seriously, there’s no such thing as a witch elm, and certainly no witches in the book. Sigh.
But there is, interestingly enough, a true story of a different wych elm and a different skeleton. Apparently, in 1943 children playing in Hagley Wood in Worchester, England, found the skull of a woman in a wych elm tree. Local police found the rest of her skeleton in the tree, and eventually established that she’d been killed in 1941. The mysterious woman was never identified, and numerous theories abounded as to who she was and how she ended up in the tree. You can read the story for yourself here and here.
So yeah, this week I’ve been busy reading and pondering. Thinking about trees and identity, and getting all excited about how people perceive me and if it’s the same way I perceive myself. I do tend to let engrossing books engross me a bit too much. And while I’ve been walking or pedalling my exercise bike, I’ve been listening to an old Ruth Rendell book. Gosh I love her writing. And I love Wexford and Burden and especially Dora. Despite the fact that they’re all about murder and mayhem, her books are calming. Not to mention restrained, deftly plotted, and very well written.
Rendell died in 2015, and to slightly misquote Shakespeare, we “shall not look upon her like again.” Have a look at her life and career in this article in The Daily Mail written by her friend A.N. Wilson. Wilson says that of Rendell’s “80 books or so” he “never found a dud.” If you’ve not read Rendell, her back list alone is a mystery lover’s nirvana.
And if reading a wonderful book, and listening to another wonderful book are not enough to create nirvana, Hubby and I have been watching Season 3 of the British mystery series The Unforgotten. I’m a big fan of Nicola Walker who plays DCI Cassie Stuart; I loved Walker in Last Tango in Halifax. Cassie heads up a team of investigators who look at cold cases. I mean, like, really cold. If you haven’t caught any of this series you should keep an eye out for it. Each season deals with one mystery. We love the way the episodes intertwine, drawing together seemingly unrelated characters and events. No pyrotechnics, no car crashes, just a well written script and some very fine acting. Goes well with a glass of wine and a bowl of popcorn. Just saying.
I’m not quite finished reading The Wych Elm or The Witch Elm, whichever. So I think I will take myself off to my sun room and finish the book before supper. Then it’s another episode of The Unforgotten for Hubby and me.
Then of course… hockey. It’s Stanley Cup season. Hubby tapes the game and, after we finish watching whatever we want together, he watches it. While I move to the sun room and try to read, or blog, and pretend he’s not regaling me with commentary on goals, penalties, bad calls, unlikely saves, whatever. After over thirty years together he still sees me as someone who understands hockey. So I ask you… are we the person we think we are, or are we the person that others see?
Still, even if we don’t share a love of hockey, we share a love of fishing, and travel, and reading. You know, it might be too much of a good thing if I loved hockey as well. Almost too much nirvana for one man to bear, you might say.
P.S. I found that shot of the wych elm tree above on a quirky site called Cumbria’s Top 50 Trees. You can read all about each specific tree, and even look at a Google map of where to find it if you want to take a stroll and look at some cool trees.
Now tell us what you’re reading, or listening to, or watching these days folks? Anything good?
You can buy Tana French’s The Witch Elm here at Amazon.
NOTE: I now have an affiliate relationship with Amazon, so if you buy the book by clicking a link in my post, I will earn a commission at no extra cost to you. NO worries if you don’t want to do that. None at all. 🙂


text:
wind quintet (2015)
Performed by Confluentes Ensemble Recorded by Jannis Lehnert, with support from the RSH Düsseldorf and the HfMT Köln (Standort Aachen)
Duration: 8 minutes
- January 27th, 2015
- Quintett Pasù
- HfMT Cologne (Germany)
About the work
The puma is one of the largest and strongest felines native to the Americas. It was a powerful symbol and the object of deep veneration for several ancient civilizations of South America, among them the Moche and the Inca. In fact, Inca admiration for the feline was so profound that their capital city, Cusco, was built in the shape of a puma, with the Saksaywaman citadel at its head, the Koricancha temple at its genitals, and a street named Pumakurku ("puma spine") along its back.
It´s quite possible to imagine why this animal deserved such extraordinary reverence. It possesses a beautiful build and great strength; its amazing speed and precision of movement make it a flawless hunter. It is also a solitary animal, which is interesting from an emotional and/or literary perspective, and makes it all the more enigmatic as a character.
I found this combination of qualities - great strength, stunning skill and a predilection for solitude - quite intriguing. Guided by these aspects, and inspired by Moche and Inca depictions of the animal, I started to explore the ritual figure of the puma through music. This work was the result.


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The Rubbermaid TakeAlongs divided food storage containers are ideal for meal prep and portion control, and are designed for a sandwich or entree and a side. The divided food container keeps wet and dry foods separate and secure so you can take your favorite food combo anywhere you want to go.
- This set of Rubbermaid food storage containers is ideal for meal prep and portion control; rectangular divided containers are perfect for wet/dry combos, fruit, pasta, snacks, and more
- Great for back to school, lunch, leftovers, and more
- Quick click Seal lids make an audible click to let you know they're securely closed
- Stackable containers have ridged lids, so they take up less space in the fridge, freezer, and cabinet
- Microwave-safe base, top-rack dishwasher-safe, freezer-safe, and BPA-free
- Set includes five 1.26-cup, five 2.35-cup and five 3.7-cup containers with lids for a total of 30 pieces
This policy is designed to ensure that you are clearly aware of our shipping policies and procedures. By ordering from this store you accept the policies contained herein.
can be calculated while check out.
Handling Time: 2 - 4 days (Monday-Saturday)
Transit Time: 5 - 8 days (Monday-Saturday)
If you change your mind before you have received your order, we are able to accept cancellations at any time before the order has been dispatched. If an order has already been dispatched, please refer to our refund policy.


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In early 2022, SEBI placed restrictions on investments in overseas securities by mutual funds (MFs), which has impacted Indian investors who look for international diversification to their portfolio.
Reasons for restrictions
Over the past few years, awareness of long-term benefits of global diversification to one’s portfolio led Indian investors to increase their exposure to equities of foreign countries like the US. MFs have been the investors’ favourite route to global investing.
Way back in 2008, SEBI and RBI set an industry-wide limit of $7 billion on investments in foreign funds and securities for the MF industry. The $7-billion limit itself was raised over time. However, this didn’t seem enough, given the rising investor appetite. Hence, earlier this year, SEBI advised MFs investing in foreign securities to stop further investments to avoid the breach of the limit, with effect from February 2, 2022.
Following SEBI’s directive, AMFI asked the fund houses to stop accepting fresh investments for schemes that invests in international securities. Apart from the industry-wide limit of $7 billion, $1-billion limit was also set at the fund house level; but even if such limit was not breached by a particular fund house, they cannot actively invest in foreign securities due to industry-wide limit being exhausted.
Though limit has been placed on fresh investments, fund houses are allowed to sell holdings from a foreign stock existing in the portfolio and buy another stock. Hence, they are allowed to shuffle across their foreign investments, but aren’t allowed to remit any fresh money.
What can investors do
While the US market correction provides good entry points, as an investor, currently, you will not be able to make fresh lumpsum/SIP/STP investments in the active international MFs and their FoF (fund of funds). However, there is a separate cap of $1 billion on ETF (exchange traded fund) schemes which invests in overseas securities and ETF FoFs. There is still certain cushion left here and you can invest through this route.
ETFs are traded on the exchanges like stocks and are passively managed as they just replicate a particular index. ETFs generally have lower expense ratio compared to an actively-managed fund, but investors need to know that ETFs might be trading in the market at a premium to NAV (Net Asset Value). Let us look at some schemes available for investors to invest through the ETF/FOF route.
Motilal Oswal NASDAQ 100 ETF replicates the US Index NASDAQ 100. Other funds investing in US equities such as Invesco EQQQ NASDAQ-100 ETF/ FoF, Kotak Nasdaq 100 ETF/ FoF, Mirae Asset S&P 500 Top 50 ETF etc. are also open.
ICICI Prudential Passive Multi Asset FoF is another fund that is open for subscription. This FoF invests in multiple asset classes. It has a universe of 30 global ETFs, out of which it invests in select ETFs according to market conditions of specific countries.
DSP Global Innovation FoF is another fund that invests in global active and passive funds and ETFs, which, in turn, invest in technology and innovation companies. Currently, owing to restrictions, it mainly invests in two ETFs such as iShares NASDAQ 100 UCITS ETF and iShares Semiconductor ETF in equal proportion.
Nippon India ETF Hang Seng BeES, which replicates Hang Seng Index, and Mirae Hang Seng Tech ETF, which replicates Hang Seng Tech Total Return Index, are also open for investments.
While investing in FoFs, investors need to know that FoFs generally tend to have higher expense ratio because of the additional layer involved.
To sidestep the restrictions on MF investing abroad, direct investing in global stocks is an option.
Indian brokerage houses such as ICICI Direct, Kotak Securities, Axis Securities etc have tie-ups with certain brokers/platforms to invest in foreign stocks. One can also directly go through platforms such as Vested Finance and Stockal.
Another way is to open an overseas trading account directly with US brokers such as Interactive Brokers, Charles Schwab and Ameritrade, among others. To open an account with US brokers, one need not have a US-based mailing address or citizenship.
Remember that for directly investing in foreign stocks, investorsneed to understand the global markets deeply and needs to do certain amount of research.


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Preoperative Oral Care May Reduce Complications From Cancer Surgery
Visiting the dentist’s office before undergoing major cancer surgery may reduce a patient’s risk of complications, according to a Japanese retrospective cohort study.
Visiting the dentist’s office before undergoing major cancer surgery may reduce a patient’s risk of complications, according to a Japanese retrospective cohort study. Published in the British Journal of Surgery, the paper, “Preoperative Oral Care and Effect on Postoperative Complications After Major Cancer Surgery,” reports that patients who visited an oral health professional were slightly less likely to develop postsurgical pneumonia or die within 30 days of surgery.
Using Japan’s nationwide administrative claims database, the researchers identified patients who were surgically treated for cancers of the head, neck, esophagus, stomach, lung, liver, colon or rectum between 2012 and 2015. The University of Tokyo investigators note that among the 509,000 subjects who had cancer surgery, 81,600 had also received preoperative oral care. When comparing this group with the remaining subjects, it was determined that preoperative oral care decreased pneumonia risk by 0.5%, and all-cause mortality within 30 days of surgery by 0.12%.
Although the preoperative oral care was not standardized, and no data were obtained on several potential confounders — including body mass index, smoking status and functional dependency — the team suggests oral care “as one option for preventing postoperative pneumonia, which can be precipitated by aspiration of oral and pharyngeal secretions.” The researchers also point out that oral health care has been found to reduce pneumonia risk for patients on ventilators.


The historic Zembo Mosque and Shrine is set to sell after almost one year on the market, according to a city spokesperson.
The 65,000-square-foot property at Division and N. 3rd streets will be sold to Arkansas-based TempleLive LLC, which plans to operate the building as a meeting, gathering and performing arts venue, city communications director Joyce Davis confirmed on Monday.
“The goal is to make it a more culturally active space,” Davis said on Monday.
TempleLive currently owns two Masonic temples similar to Zembo, one in Cleveland and one in Fort Smith, Ark. They run both properties as a multi-purpose event spaces, according to the venues’ websites.
Mike Brown, vice president of acquisitions for Beaty Capital Group, TempleLive’s parent company, expects the sale to close at the end of March or beginning of April. He hopes the site will be operational by the fall.
“The sooner, the better,” Brown said.
Brown said it was too early to tell if the building would require extensive renovations, but he did say that the shrine’s main auditorium would need air conditioning. He claimed that TempleLive representatives visited the site three or four times before entering the sale agreement.
Brown declined to disclose the final sale price and did not know if the buyers would take advantage of a tax abatement.
The Zembo shrine went on the market in February 2017 with a $950,000 asking price. Davis could not confirm the property’s final sale price, which was reportedly reached at a special meeting on Jan. 11.
The deal was brokered by the Bill Gladstone Group of NAI CIR, a commercial real estate agency in Lemoyne, and includes 396 parking spaces adjacent to the building.
Since its opening, Zembo has been home to the Shriners, a fraternal organization affiliated with the Free Masons. The Shriners continue to meet there today, but the group’s declining membership, coupled with the building’s high operating costs, forced them to sell the historic property.
Zembo was constructed in 1930 in a Moorish Revival architectural style. The building features interior arches, hand-painted motifs, and ornate stone detailing. It houses large meeting rooms and a theater with a 2,500-seat capacity.
The building faces Italian Lake and former William Penn High School. That vacant campus is also currently for sale.
In a statement issued on Monday, Mayor Eric Papenfuse praised the sale of the historic Zembo building and the plans to make it a touristic attraction within the city.
“This is a truly wonderful development for our city,” Papenfuse said.
This article was updated to include comments from Mike Brown.


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Biplov led NCP Cadre surrenders
Former District member Yagya Prasad Sapkota of Biplov led Nepal Communist Party, of Thakurbaba Municipality-7 has surrendered himself to the District Administration Office on April 9.
He presented himself in front of District Administration Office and committed of not involving in any activities of the party.
Chief District Officer Ram Bahadur Kurubang of Bardiya confirmed his surrender and added that he is given a chance to correct himself.
Similarly, 66 years old Chunni Khan of Khajura Rural Municipality-8 surrendered along with the written commitment of not involving in Biplov led activities.
After the political intervention , Dilli Bahadur BC of Nepalgunj metropolis, Ram Ji Kunwar of Kohalpur and Gagan Khadka of Rukum Chaujahari have already surrendered to District Administration Office according to SP Arun Paudel of DPO.
Man Bahadur Chaudhary
Archeologically Important Assembly Hall Operating Children’s Home (Bal Mandir) Dilapilated.
Children’s Home (Bal Mandir) operating in an ancient assembly hall, with archeological significance, in Dhunche, Rasuwa headquarters, was destroyed due to the devastating earthquake of 2015. It is still in…
Police Complaint Registered Against Accused of Sexual Abuse
The victim filed a complaint against Devjan Sarki, 22, of Sarkegad rural municipality-1, Jair, on 24 March 2023 for sexually abusing a 17-year-old girl. DSP Bhimalal Bhattarai said that the…
Rape Accused Sentenced to 19 years Imprisonment
The Dailekh District Court sentenced Sibu Tamang, 26, a resident of Panchkhaal Municipality-6, Kavre District, to 19 years imprisonment on the charge of rape of a 13-year-old girl. Information…
Accused of Rape Sentenced to 19 Years Imprisonment
The district court sentenced Jitendra B.K, 19, Municipality-1 of Musikot to 19 years of imprisonment and compensation of Rs. 7,00,000, on 24 March 2023. District Court record-keeper, Ram Bahadur Kuwar,…
INSEC Provides Financial Support to Victim of Rape
INSEC Lumbini Province Office, Nepalgunj, provided financial assistance for legal support, of Rs. 8,000 to a 40-year-old rape victim on 25 March 2023, the legal process. The victim had filed…


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The late Martin Amis once wrote about Middlemarch that it is a ‘novel without weaknesses’. You might say something similar about The Fraud – The Guardian
An ingenious, unresolved tale told by a writer at the peak of her powers – The Daily Telegraph
Zadie Smith is one of Britain’s best-loved novelists. Her body of work includes three essay collections, a short-story collection, and six acclaimed novels, including White Teeth and On Beauty (which was short-listed for the Man Booker Prize and won the 2006 Orange Prize for fiction).
Smith’s new novel, The Fraud, was named in December as one of the ten best books of 2023 by the staff of The New York Times Book Review. That accolade capped the widespread acclaim that greeted Smith’s novel – her first in seven years and her first historical novel – after its publication in September.
On June 17 Zadie Smith comes to the Intelligence Squared stage to talk about The Fraud and her writing career, and to mark the publication of the paperback edition of the novel.
The Fraud’s main characters are all based on historical figures – including novelists, alleged fraudsters, freed slaves – who lived in Smith’s own London neighbourhood of Kilburn. But the novel is as international as it is local and it addresses issues of politics and identity that make The Fraud feel as much about today as about the past.
Join us live at Union Chapel and put your questions to one of today’s leading novelists.
by Zadie Smith
Kwame Kwei-Armah OBE is Artistic Director of the Young Vic Theatre and Artistic Advisor at Manhattan Theatre Club in New York. He was previously Artistic Director of Baltimore Center Stage (2011-18) and Artistic Director of the Festival of Black Arts and Culture, Senegal (2010), where he wrote and directed the opening ceremony at Senghor stadium. As a playwright, Kwame was the first black Briton to have a play produced in London’s commercial West End (Elmina’s Kitchen). His triptych of plays was produced at the National Theatre, where he later created the online resource The Black Play Archive.
Kwame was Chancellor of the University of the Arts, London (2010-2015), is Patron of Ballet Black and The Black Cultural Archives, Chair of Warwick Arts Centre Advisory Board and a Trustee of the Tate and the founding Trustee Black Equity Organisation. Kwame was awarded an OBE for Services to Drama in 2011, and in 2020 listed as one of 100 Great Black Britons.


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|Title (Primary)||Quantification of individual flagellate - bacteria interactions within semi-natural biofilms|
|Author||Erken, M.; Farrenschon, N.; Speckmann, S.; Arndt, H.; Weitere, M.|
|Keywords||Biofilms; flagellates; flow cells; grazing rates; video 28 microscopy|
Here we present a new approach to quantify food-web interactions within semi-natural biofilms by combining the establishment of biofilms from natural rivers in flow cells with video microscopy. In a first application of this approach, we focused on the surface-gliding heterotrophic flagellates (HF) Neobodo designis, Rhynchomonas nasuta and Planomonas sp. It was shown that the three HF generally ingested single biofilm-associated bacteria whereas bacteria within microcolonies were attacked but not ingested. However, grazing strategies differed considerably. While the kinetoplastids N. designis and R. nasuta displayed long search and short handling times, Planomonas sp. showed the opposite grazing characteristics. The latter behaviour resulted in a high relative predation success of 80% (precent of attacked prey ingested), whereas the relative predation success of the two kinetoplastids was only 20%. However, the two contrasting strategies resulted in similar ingestion rates for Planomonas sp. and N. designis of 0.5 to 0.6 ingestions flagellates−1 minute−1, respectively. Our results showed distinct differences in the feeding behaviour of three flagellates having similar life forms and provide direct evidence that microcolony formation in biofilms protects bacteria from grazing by HF in situ.
|Persistent UFZ Identifier||https://www.ufz.de/index.php?en=20939&ufzPublicationIdentifier=11839|
|Erken, M., Farrenschon, N., Speckmann, S., Arndt, H., Weitere, M. (2012):
Quantification of individual flagellate - bacteria interactions within semi-natural biofilms
Protist 163 (4), 632 - 642

domain: biology