Incorporation of the United Nations Convention on the Rights of the Child in Law: A Comparative Review

Incorporation in law is recognised as key to the implementation of the UNCRC. This article considers the ways in which a variety of countries have chosen to incorporate the CRC, drawing on a study conducted by the authors for UNICEF-UK. It categorises the different approaches adopted into examples of direct incorporation (where the CRC forms part of domestic law) and indirect incorporation (where there are legal obligations which encourage its incorporation); and full incorporation (where the CRC has been wholly incorporated in law) and partial incorporation (where elements of the CRC have been incorporated). Drawing on evidence and interviews conducted during field visits in six of the countries studied, it concludes that children’s rights are better protected – at least in law if not also in practice – in countries that have given legal status to the CRC in a systematic way and have followed this up by establishing the necessary systems to support, monitor and enforce the implementation of CRC rights.

Bills of Rights:A Comparative Perspective

Bills of rights are currently a much debated topic in various jurisdictions throughout the world. Almost all democratic nations, with the exception of Australia, now have a bill of rights. These take a variety of forms, ranging from constitutionally entrenched bills of rights, such as those of the United States and South Africa, to non-binding statements of rights. Falling between these approaches are non-entrenched, statutory bills of rights. As regards the latter, a model which has become increasingly popular is that of bills of rights based on interpretative obligations, whereby duties are placed upon courts to interpret national legislation in accordance with human rights standards. The aim of this book is to provide a comparative analysis of the bills of rights of a number of jurisdictions which have chosen to adopt such an approach. The jurisdictions considered are New Zealand, the United Kingdom, the Australian Capital Territory and the Australian state of Victoria.

There have been very few books published to date which contain a detailed comparative analysis of the bills of rights which this book addresses. The book adopts a unique thematic approach, whereby six aspects of the bills of rights in question have been selected for comparative analysis and a chapter is allocated to each aspect. This approach serves to facilitate the comparative discussion and emphasise the centrality of the comparative methodology.

Comparative study of tool life and hole quality in drilling of CFRP/titanium stack using coated carbide drill

The use of hybrid materials including carbon fiber reinforced plastics (CFRPs) and lightweight metals such as titanium are increasing particularly in aerospace applications. Multi-material stacks require a number of holes for the assembly purposes. In this research, drilling trials have been carried out in CFRP, Ti-6Al-4V and CFRP/Ti-6Al-4V stack workpieces using AlTiN coated tungsten carbide drill bit. The effects of process parameters have been investigated. The thrust force, torque, burr formation, delamination, surface roughness and tool wear have been analyzed at various processing condition. The experimental results have shown that the thrust force, torque, burr formation and the average surface roughness increase with the increased feed rate and decrease with the increased cutting speed in drilling of Ti-6Al-4V. In drilling CFRP, delamination and the average surface roughness has similar tendency with the cutting parameters however thrust force and torque rises with the increased cutting speed. The results showed that after making 15 holes in CFRP/Ti-6Al-4V stack, measured thrust forces were increased by 20% in CFRP and by 45% in Ti-6Al-4V. Delamination was found to be much smaller in drilling of CFRP in stack from compared to drilling single CFRP. Tool life was significantly shortened in drilling of stack due to the combination of the wear mechanisms.

Healthcare in Ireland and Britain 1850-1970: Voluntary, regional and comparative perspectives

This volume explores developments in health and social care in Ireland and Britain during the nineteenth and twentieth centuries. The central objectives are to highlight the role of voluntarism in healthcare, to examine healthcare in local and regional contexts, and to provide comparative perspectives. The collection is based on two interconnected and overlapping research themes: voluntarism and healthcare, and regionalism/localism and healthcare. It includes two synoptic overviews by leading authorities in the field, and ten case studies focusing on particular aspects of voluntary and/or regional healthcare in Ireland and Britain.

Regulating Services Trade Agreements - A Comparative Analysis of Regulatory Disciplines Included in EU and US Free Trade Agreements

Developed countries, led by the EU and the US, have consistently called for ‘deeper integration’ over the course of the past three decades i.e., the convergence of ‘behind-the-border’ or domestic polices and rules such as services, competition, public procurement, intellectual property (“IP”) and so forth. Following the collapse of the Doha Development Round, the EU and the US have pursued this push for deeper integration by entering into deep and comprehensive free trade agreements (“DCFTAs”) that are comprehensive insofar as they are not limited to tariffs but extend to regulatory trade barriers. More recently, the EU and the US launched negotiations on a Transatlantic Trade and Investment Partnership (“TTIP”) and a Trade in Services Agreement (“TISA”), which put tackling barriers resulting from divergences in domestic regulation in the area of services at the very top of the agenda. Should these agreements come to pass, they may well set the template for the rules of international trade and define the core features of domestic services market regulation. This article examines the regulatory disciplines in the area of services included in existing EU and US DCFTAs from a comparative perspective in order to delineate possible similarities and divergences and assess the extent to which these DCFTAs can shed some light into the possible outcome and limitations of future trade negotiations in services. It also discusses the potential impact of such negotiations on developing countries and, more generally, on the multilateral process.

Range expansion and comparative habitat use of insular, congeneric lagomorphs: invasive European hares Lepus europaeus and endemic Irish hares Lepus timidus hibernicus

The European hare (Lepus europaeus) has declined throughout its native range but invaded numerous regions where it has negatively impacted native wildlife. In southern Sweden, it replaces the native mountain hare (L. timidus) through competition and hybridisation. We investigated temporal change in the invasive range of the European hare in Ireland, and compared its habitat use with the endemic Irish hare (L. timidus hibernicus). The range of the European hare was three times larger and its core range twice as large in 2012–2013 than in 2005. Its rate of radial range expansion was 0.73 km year−1 with its introduction estimated to have occurred ca. 1970. Both species utilised improved and rough grasslands and exhibited markedly similar regression coefficients with almost every land cover variable examined. Irish hares were associated with low fibre and high sugar content grass (good quality grazing) whilst the invader had a greater tolerance for low quality forage. European hares were associated with habitat patch edge density, suggesting it may be more suited to using hedgerows as diurnal resting sites than the Irish hare. Consequently, the invader had a wider niche breadth than the native but their niche overlap was virtually complete. Given the impact of the European hare on native species elsewhere, and its apparent pre-adaption for improved grasslands interspersed with arable land (a habitat that covers 70 % of Ireland), its establishment and range expansion poses a significant threat to the ecological security of the endemic Irish hare, particularly given their ecological similarities.

Comparative biochemical analysis of three members of the Schistosoma mansoni TAL family: Differences in ion and drug binding properties

The tegumental allergen-like (TAL) proteins from Schistosoma mansoni are part of a family of calcium binding proteins found only in parasitic flatworms. These proteins have attracted interest as potential drug or vaccine targets, yet comparatively little is known about their biochemistry. Here, we compared the biochemical properties of three members of this family: SmTAL1 (Sm22.6), SmTAL2 (Sm21.7) and SmTAL3 (Sm20.8). Molecular modelling suggested that, despite similarities in domain organisation, there are differences in the three proteins’ structures. SmTAL1 was predicted to have two functional calcium binding sites and SmTAL2 was predicted to have one. Despite the presence of two EF-hand-like structures in SmTAL3, neither was predicted to be functional. These predictions were confirmed by native gel electrophoresis, intrinsic fluorescence and differential scanning fluorimetry: both SmTAL1 and SmTAL2 are able to bind calcium ions reversibly, but SmTAL3 is not. SmTAL1 is also able to interact with manganese, strontium, iron(II) and nickel ions. SmTAL2 has a different ion binding profile interacting with cadmium, manganese, magnesium, strontium and barium ions in addition to calcium. All three proteins form dimers and, in contrast to some Fasciola hepatica proteins from the same family; dimerization is not affected by calcium ions. SmTAL1 interacts with the anti-schistosomal drug praziquantel and the calmodulin antagonists trifluoperazine, chlorpromazine and W7. SmTAL2 interacts only with W7. SmTAL3 interacts with the aforementioned calmodulin antagonists and thiamylal, but not praziquantel. Overall, these data suggest that the proteins have different biochemical properties and thus, most likely, different in vivo functions.

Comparative Law and European Harmonisation - a Match Made in Heaven or Uneasy Bedfellows?

Developing the controversy indicated in the heading, this article will proceed as follows. It establishes a notion of critical comparative law, by showing how comparative law may be capable of providing critique and analysis of law-making through judicial and legislative activity at a European level. This is followed by an exemplary discussion of how comparative law is actually used in relation to European harmonisation through case law, legislation and “soft law”. The question will then be asked whether and how these uses would change under a critical approach to comparative law. The discussion will focus on industrial relations and equality law.
In both fields, recent ECJ case law has proved controversial: This article submits that such controversy could partly be avoided by making better use of critical comparative law in deciding cases and in choosing adequate forms and content of legislation.