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Mako Participates in Conference on Iraq, Its Challenges, and Future Opportunities
On October 26, 2022, Shamiran Mako, Assistant Professor of International Relations at Boston University’s Frederick S. Pardee School of Global Studies, participated in a conference hosted by the Atlantic Council’s Iraq Initiative on Iraq, its evolution over the past two decades, and its democratic transition.
The two-day conference, titled “Turmoil and transition: Iraq twenty years after the invasion,” explored Iraq’s past two decades of change and upheaval and the key challenges and opportunities confronting future generations in Iraq. Mako was joined on the panel by Feisal Al-Istrabadi, Founding Director of the Center for the Study of the Middle East and McRobbie Professor in Global Strategic Studies at Indiana University, Bloomington; Laith Kubba, an independent advisor on Iraq; as well as Sarkawt Shamsuddin, a former member of Iraqi Parliament. The session, titled “Iraq’s democratic experience,” was moderated by Wall Street Journal reporter Vivian Salama.
During the session, panelists discussed the political instability in Iraq, the country’s new government headed by Prime Minister Mohammed Shia’ al-Sudani, and the challenges ahead for both the country’s leaders and its people. Mako argues that one of the biggest challenges facing the new government is instilling a sense of confidence in the Iraqi populace, which she argues can only be accomplished by entrenching much-needed institutional reforms and engaging in more conciliatory politics, even when there are many strategic alliances. Unfortunately, the speakers noted that the political system in Iraq remains corrupt and dysfunctional meaning reforms will be difficult. Mako stressed that Iraq was not a functioning democracy; it was always an elite game in terms of how government operates.
The full panel can be viewed below.
Shamiran Mako is an assistant professor of international relations at the Pardee School of Global Studies at Boston University. She is also a member of the Graduate Faculty at the Political Science Department at Boston University. Her research explores the historical and contemporary drivers of inter and intra-state conflicts that produce weak and fragile states across the MENA region. She is the author of After the Uprisings: Progress and Stagnation in the Middle East and North Africa, with Valentine Moghadam. Read more about Professor Mako on her faculty profile.
Posted 3 months ago in Events News
Tagged: 2022, Atlantic Council, Democratic Transition, Iraq, Shamiran Mako
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Home / Car Accidents
By Warren & Kallianos, PLLC | September 7, 2021 | 0
From our very first memories of riding in a car as a child, the notion of wearing a seatbelt was always actively enforced by parents, teachers, and authorities. As time continues and we all become of age to drive, we are still reminded of the importance of wearing a seatbelt, whether we are behind the…
Precautions for North Carolina’s Delivery Drivers
By Warren & Kallianos, PLLC | June 2, 2020 | 0
Due to the COVID-19 pandemic, truck drivers and delivery drivers have literally become the lifeblood of our economy. Amazon truck drivers and truck drivers for grocery stores, clothing stores, and other retail stores are proving the essential products we need to survive. Many people are using food delivery services such as Instacart, Grubhub, restaurant drivers,…
He Said/He Said: How a Charlotte Car Accident Lawyer Builds Your Case
By Warren & Kallianos, PLLC | May 12, 2020 | 0
Car accidents can be traumatic, even when someone doesn’t suffer permanent injuries. In order to be successful in your claim for damages, you need to determine liability: who is accountable for the crash. But what can you do when you say “A,” and the other driver says “B”? When you have been hurt and the…
The Real Cost of Aggressive Driving
By Warren & Kallianos, PLLC | December 17, 2019 | 0
Driving can be a very enjoyable activity. You get out on the open road, and put the windows down to get a fresh breeze while singing along to your favorite music. It’s relaxing – however, when you wind up doing a lot of driving, you begin to encounter people making vehicle maneuvers that should be…
Five Safety Tips for Parents of Teen Drivers
Parents of new teen drivers live with a two-fold sense of anxiety: first, they are worried about their child’s life each time they get behind the wheel, and they are concerned for the lives of the other drivers on the road should their child’s lack of experience cause a crash that hurts someone else. Because…
Where Are Charlotte’s Most Dangerous Intersections?
By Warren & Kallianos, PLLC | June 18, 2018
Have you ever gone through a dicey intersection in Charlotte and driven away convinced that it is the worst intersection in the city? Well, you may be right. Even though you can get into a car accident when you go through pretty much any intersection, statistics show that your odds greatly increase at certain locations within…
What to Keep in Your Car in Case of an Emergency
By Warren & Kallianos, PLLC | April 30, 2018
You can encounter an emergency situation any time you get into your car and hit the road. Unfortunately, one of the risks that you face in Charlotte and throughout North Carolina is the risk of getting into an auto accident. This is true even if you are a highly safe driver. The reality is that…
How to File a Car Accident Claim in North Carolina
By Warren & Kallianos, PLLC | February 15, 2017
In the aftermath of a serious car crash, you may be left facing the high costs of vehicle repairs or replacement, while suffering severe injuries that require ongoing medical care and treatment. If another person was to blame for your car accident, you should be entitled to pursue compensation to cover these and other costs.…
What Should I Do after a Car Accident?
By Warren & Kallianos, PLLC | October 13, 2016
There were a total of 1,379 fatal traffic crashes in North Carolina during 2015, the National Highway Traffic Safety Administration reports. This number does not include the thousands of other car accidents that occurred throughout the state that were not fatal, but did result in injuries and property damage. The numbers are not only heart-wrenching,…
North Carolina Police Involved in Hundreds of Accidents Annually
According to a recent report by a Raleigh-Durham area television station, North Carolina Highway Patrol (NCHP) vehicles averaged one accident per day in 2009. State records indicate that, when compared to the number of accidents reported in 2008, trooper-involved accidents increased 44 percent. This number may seem shockingly excessive, but when put into the context…


Nerve Transfer Clinical Trial for Chronic Cervical SCI
Hand function is consistently ranked as the most desired function to regain in the case of impairment due to spinal cord injury (SCI), even above that of bowel and bladder. It stands to reason—with approximately half of SCI occurring in the cervical spine—that The Miami Project to Cure Paralysis researchers have directed their attention on recovery of upper extremity function. Dr. S. Shelby Burks, M.D., a burgeoning academic neurosurgeon in the Department of Neurological Surgery, under Miami Project Clinical Director Allan Levi, M.D., Ph.D., is our site Principal Investigator on a new multi-center nerve transfer clinical trial examining the effect of nerve transfers on reaching and grasping function, and quality of life, in people with tetraplegia.
Traumatic SCI, defined as an injury caused by physical insult to the nerves within the spinal cord, interrupts signals traveling through the central nervous system. In many cases, however, the nerves that exit the spine at nerve root, located below the level of injury are still capable of conducting or transmitting signals. The problem with these nerves is input, not transmission. It has long been established that peripheral nerve axons have the capacity to naturally regenerate—unlike their central nervous system counterparts that will require external modification to do so. Combined, surgeons have realized that peripheral nerves originating from roots above the injury can be cut, repositioned, and then fixed into different peripheral nerve that arises from below the level of injury. This nerve transfer allows for the signal generated by a nerve supplied at a higher level above the injury to be transferred down the nerve normally supplied by a lower level below the injury.
Although numerous clinical trials have been conducted in cervical SCI population, thus far no efficient treatment has been established. The central nervous system, particularly the spinal cord, seems to be extremely challenging when it comes to inducing regeneration. The design of this nerve transfer clinical trial intends to circumvent the issue with as yet unsuccessful attempts to regenerate the spinal cord after the injury. The approach is possible because above the injury, the spinal cord is completely intact, while below the injury, the peripheral nerves are also still capable of sending signals down their axons. Therefore, reattaching a nerve from above the injury, which has seemingly redundant function to the otherwise latent nerve below the injury allows for existing signals to be rerouted to activate previously paralyzed muscles. With targeted motor relearning, the restored signals to sublesional muslces could increase the quality of life of people with SCI.
Nerve transfer surgeries, especially those to treat brachial plexus and peripheral nerve injuries, have become increasingly popular in the last 25 years. When compared to grafting and regeneration strategies within the spine, these surgeries reestablish contraction and functional outcomes over reproducible timelines. Only recently have nerve transfer surgeries been considered as potential treatment options for patients with cervical SCI.
This nerve transfer clinical trial, therefore, aims to broaden the evidence base for the clinical benefits of cervical nerve transfer in tetraplegia. The overall trial, funded by the United States Department of Defense, is headed by Dr. Wilzon Z. Ray, M.D., at Washington University School of Medicine and involves at least eight sites in the United States and Canada with The Miami Project’s efforts lead by Dr. Burks. Soon, once The Miami Project has finalized the regulatory onboarding process, recruitment will begin seeking participants who meet the study’s inclusion criteria. The trial is registered with the U.S. National Library of Medicine under the identifier NCT04023591. This study demonstrates the expanded potential afforded by a diversification of The Miami Project’s portfolio of expertise across various neurological conditions.
The Miami Project and Buoniconti Fund want to wish


by Alexander Maxwell August 17, 20211:55 pm August 15, 2021
Meet Richard Springfield: a Successful Businessman Making Entrepreneurship Look Easy
Entrepreneur and business coach Richard Springfield is here to create a shift in the mindset of the masses in the way we perceive finances. He’s created his own thriving business focused on providing the financial literacy needed to break the boundaries of what earning an income looks like in the digital age. Today he’s here to share his story of pushing through problems to rise to the top.
Born and raised in Los Angeles, California, Richard, who goes by Rich, attended San Francisco State University to study business. It was coming into the university that led Rich to learn of the numerous possibilities within the realm of entrepreneurship.
When discussing how his time in school propelled him into his future as a successful business owner, Rich says:
“When I came into college I was learning about business in the context of getting a blue or white-collar job. But during my time there I was networking with a lot of different people who were also looking for more for themselves outside of just getting an education to go get a job after graduating. I started to learn more about entrepreneurship and the different avenues within it, like real estate and investing. It made me realize that there’s so much more information out there that you can’t learn in school, you can only get it from experience.”
Before graduating from University with his business degree in 2019, Rich was introduced to the concept of network marketing and trading in the financial markets which would give him the real-world experience he was looking for in investing and starting a business. To date, Rich has created his own organization called Minute Made Money focused on helping individuals become educated investors and entrepreneurs with a keen focus on internal growth to achieve financial and personal goals.
When discussing the concept behind his business, Rich says:
“The objective of Minute Made Money is to inspire and educate people all over the world. We work with any individual willing to work towards achieving financial independence through a different avenue than a 9-5 job, while also becoming a better version of themselves in the process. We provide a platform for the best of the best information and education from the top-down to help people increase their financial literacy. Our members are able to learn from top traders and leaders in the industry. It’s all about having access to the information that can change your life, and we’re helping to provide it.”
Currently, Minute Made Money contains over 100 like-minded individuals and counting all working towards a common goal of development financially and personally. Not only is Rich focused on helping people create additional sources of income, he’s also dedicated to making an impact on people’s lives that goes far beyond monetary value.
Growing up in Los Angeles and being involved with a friend group who did not always have Rich’s best interests at heart, Rich found himself in the wrong place at the wrong time on multiple occasions especially leading up to his start in college. It took internal reflection and discipline for Rich to make the decision that real change and more accountability were needed in order to improve the outlook of his future and align his current path with the goals he had for himself.
To this day, Rich believes that the circle you keep is crucial to the outcomes you produce in life. Through Minute Made Money, he strives to keep a positive and uplifting culture amongst his team, where everyone is encouraged to be the best possible version of themselves.
With the future of Minute Made Money looking bright, Rich plans on expanding into other philanthropic business ventures, looking to give back to the city he calls home.
“I want to start more businesses, like stem programs and financial literacy programs so kids can get the information they need at an early age to set themselves up for success in their futures. Being able to manage your money is a crucial skill and it’s not taught in school. I want to make sure that kids from my community have access to that. Starting early with these skills is important as technology is changing and new ways to earn an income are always emerging,” says Rich.
A pivotal moment in Rich’s life was the passing of his father to COVID-19. After such a devastating loss that Rich and his family are still recovering from to this day, Rich realized the fragility of life and the importance of making the most out of every single opportunity. Rich’s faith was strengthened after the experience as he learned to navigate the new hardship of living without his father, but he has been able to remain strong in his belief that every new challenge we are brought to in life, we can handle.
As a budding businessman with his entrepreneurial ventures flourishing, there is no doubt we can expect to see more inspiring and impactful projects from Rich in the near future. In closing, Rich leaves his best pieces of advice for the aspiring entrepreneur:
Never give up on what you started. “There’s a lot of ups and downs in business and entrepreneurship, and a lot of the time when people are down they end up giving up on their dreams. The only way to get to your end goal is if you don’t give up.”
Pressure builds diamonds.“For me, I perform even better under pressure. Everyone gets nervous, but being in that situation where you have that pressure on you is what’s going to grow you.”
Listen to your mentor. “Find a mentor who has what you want and does what they do. If you surround yourself with nine millionaires, you’ll be the tenth.”
Alexander Maxwell
Internet Entrepreneur | Digital Marketing Expert | Marketing Consultant | Stock Market Enthusiast|| Founder & CEO at Maxwell Digitals, based in California.


The Computers are Listening
Posted by aurelius77 on May 6, 2015
How the NSA Converts Spoken Words Into Searchable Text
Most people realize that emails and other digital communications they once considered private can now become part of their permanent record.
But even as they increasingly use apps that understand what they say, most people don’t realize that the words they speak are not so private anymore, either.
Top-secret documents from the archive of former NSA contractor Edward Snowden show the National Security Agency can now automatically recognize the content within phone calls by creating rough transcripts and phonetic representations that can be easily searched and stored.
The documents show NSA analysts celebrating the development of what they called “Google for Voice” nearly a decade ago.
Though perfect transcription of natural conversation apparently remains the Intelligence Community’s “holy grail,” the Snowden documents describe extensive use of keyword searching as well as computer programs designed to analyze and “extract” the content of voice conversations, and even use sophisticated algorithms to flag conversations of interest.
The documents include vivid examples of the use of speech recognition in war zones like Iraq and Afghanistan, as well as in Latin America. But they leave unclear exactly how widely the spy agency uses this ability, particularly in programs that pick up considerable amounts of conversations that include people who live in or are citizens of the United States.
Spying on international telephone calls has always been a staple of NSA surveillance, but the requirement that an actual person do the listening meant it was effectively limited to a tiny percentage of the total traffic. By leveraging advances in automated speech recognition, the NSA has entered the era of bulk listening.
And this has happened with no apparent public oversight, hearings or legislative action. Congress hasn’t shown signs of even knowing that it’s going on.
The USA Freedom Act — the surveillance reform bill that Congress is currently debating — doesn’t address the topic at all. The bill would end an NSA program that does not collect voice content: the government’s bulk collection of domestic calling data, showing who called who and for how long.
Even if becomes law, the bill would leave in place a multitude of mechanisms exposed by Snowden that scoop up vast amounts of innocent people’s text and voice communications in the U.S. and across the globe.
Civil liberty experts contacted by The Intercept said the NSA’s speech-to-text capabilities are a disturbing example of the privacy invasions that are becoming possible as our analog world transitions to a digital one.
“I think people don’t understand that the economics of surveillance have totally changed,” Jennifer Granick, civil liberties director at the Stanford Center for Internet and Society, told The Intercept.
Extensive Use Abroad
Voice communications can be collected by the NSA whether they are being sent by regular phone lines, over cellular networks, or through voice-over-internet services. Previously released documents from the Snowden archive describe enormous efforts by the NSA during the last decade to get access to voice-over-internet content like Skype calls, for instance. And other documents in the archive chronicle the agency’s adjustment to the fact that an increasingly large percentage of conversations, even those that start as landline or mobile calls, end up as digitized packets flying through the same fiber-optic cables that the NSA taps so effectively for other data and voice communications.
The Snowden archive, as searched and analyzed by The Intercept, documents extensive use of speech-to-text by the NSA to search through international voice intercepts — particularly in Iraq and Afghanistan, as well as Mexico and Latin America.
For example, speech-to-text was a key but previously unheralded element of the sophisticated analytical program known as the Real Time Regional Gateway (RTRG), which started in 2005 when newly appointed NSA chief Keith B. Alexander, according to the Washington Post, “wanted everything: Every Iraqi text message, phone call and e-mail that could be vacuumed up by the agency’s powerful computers.”
The Real Time Regional Gateway was credited with playing a role in “breaking up Iraqi insurgent networks and significantly reducing the monthly death toll from improvised explosive devices.” The indexing and searching of “voice cuts” was deployed to Iraq in 2006. By 2008, RTRG was operational in Afghanistan as well.
A slide from a June 2006 NSA powerpoint presentation described the role of VoiceRT:
Extent of Domestic Use Remains Unknown
What’s less clear from the archive is how extensively this capability is used to transcribe or otherwise index and search voice conversations that primarily involve what the NSA terms “U.S. persons.”
The NSA did not answer a series of detailed questions about automated speech recognition, even though an NSA “classification guide” that is part of the Snowden archive explicitly states that “The fact that NSA/CSS has created HLT models” for speech-to-text processing as well as gender, language and voice recognition, is “UNCLASSIFIED.”
Also unclassified: The fact that the processing can sort and prioritize audio files for human linguists, and that the statistical models are regularly being improved and updated based on actual intercepts. By contrast, because they’ve been tuned using actual intercepts, the specific parameters of the systems are highly classified.
“The National Security Agency employs a variety of technologies in the course of its authorized foreign-intelligence mission,” spokesperson Vanee’ Vines wrote in an email to The Intercept. “These capabilities, operated by NSA’s dedicated professionals and overseen by multiple internal and external authorities, help to deter threats from international terrorists, human traffickers, cyber criminals, and others who seek to harm our citizens and allies.”
Full article: The Computers are Listening (The//Intercept)
This entry was posted in Afghanistan, Business & Economics, Espionage, Government Corruption, Iraq, Mexico, National Security & Terrorism, Politics, USA and tagged Afghanistan, Business & Economics, cellular networks, conversations, domestic use, Edward Snowden, Espionage, fiber-optic cables, Google, Google for Voice, government corruption, international voice intercepts, Iraq, Jennifer Granick, Keith B. Alexander, landlines, Latin America, Mexico, mobile calls, National Security & Terrorism, National Security Agency, NSA, NSA surveillance, phone lines, politics, Real Time Regional Gateway, RTRG, searchable text, Skype, speech recognitionw, spoken word, Stanford Center for Internet and Society, The Computers are Listening, United States, Vanee’ Vines, voice communications, voice-over-internet services. Bookmark the permalink.
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Jimmy Choi: JC Fox Ninja and Advocate
Parkinson’s disease (or PD) is typically recognized as a “movement disorder.” However, PD is actually a neurodegenerative disease, made up of a constellation of movement and non-movement symptoms, including sleep disorder, gut dysfunction, depression, and difficulties with executive function and memory1. In many cases, Parkinson’s disease also involves Lewy Body dementia (LBD), which results in hallucinations and delirium. It is estimated there are over 1 million people in the United States with Parkinson’s, making it the second most common neurodegenerative disease behind Alzheimer’s. And, much like Alzheimer’s, despite the tremendous challenges faced by patients and their families, there are very special individuals in the Parkinson’s community making extraordinary contributions to awareness, advocacy, and brain-healthy living in general.
One such person is Jimmy Choi, affectionately known as the “Fox Ninja”. For people familiar with the American Ninja Warrior series on TV, you may have seen Jimmy jumping, swinging, and climbing his way through the show’s famous obstacle courses for 5 seasons from 2017 to 2021. To be an ANW contestant is to be an athlete with tremendous strength, flexibility, and coordination. What makes Jimmy unique? He’s an American Ninja Warrior, and he happens to have Parkinson’s disease. How does a person like Jimmy - with a disease known for tremors, stiffness, and slowness - work his way up to competing with elite athletes? Read on. His story is an inspiration in overcoming the stigma of Parkinson’s and using it to raise awareness and fund cutting-edge research.
From Denial to Taking Control
In 2003, at the age of 27, Jimmy was diagnosed with young onset Parkinson’s disease. In hindsight, Jimmy acknowledges that he must have been feeling symptoms from his early 20’s. He had difficulty throwing balls. For some reason, he experienced a lack of brain-hand coordination, and the balls went straight into the ground. Later, a nurse performing his life insurance evaluation shared with him that she worked for a neurologist. She didn’t mention Parkinson’s, but she strongly encouraged him to see a movement disorder specialist. Upon doing so, Jimmy was diagnosed with Young Onset Parkinson’s Disease. For a disease that’s typically diagnosed after the age of 60, he was understandably in denial, but multiple neurologist visits came to the same conclusion: Parkinson’s disease. He didn’t tell his wife Cherryl of his diagnosis for months, let alone manage his symptoms at the beginning. However, by 2010, he was overweight and walking with a cane. It was in that year when he had his “wake up” call. Jimmy fell down the stairs while carrying his toddler son. At the bottom of the stairs, Jimmy committed himself to do the best he could for his family and show them that he will never give up. It was time to take control and engage with his condition and the Parkinson’s community.
Jimmy started physical therapy, which led him to running, and after some extensive research he learned that exercise was one of the best ways to slow progression of Parkinson's. By starting small with walks around the block with his cane, he was soon walking without his cane - and then jogging. Then, he joined Team Fox (a grassroots community fundraising program of the Michael J. Fox Foundation) in 2012 and ran his first marathon that year, raising money for the organization. One marathon turned into a few, and he even competed in an ultra-marathon (that’s 50 miles!).
American Ninja Warrior and Beyond
If that wasn't inspiring enough, Jimmy took it to the next level in 2016 when he challenged himself to qualify and compete in NBC's American Ninja Warrior. The motivation came from his daughter, Karina, who’d been training at a “ninja gym,” and she encouraged her dad to try out to be an American Ninja Warrior (her favorite show). So, with similar conviction as his marathon training, he dedicated himself to “ninja training” to show the world that Parkinson's would not get the best of him. Despite the physical and mental challenges of the disease, he competed in 2017 and in each of the next 4 years, and he’s raised awareness about Parkinson's all along.
On top of that, when the pandemic hit, Jimmy showed countless people that you could stay fit in “quarantine” by breaking two fitness world records to raise funds for Parkinson’s disease research. It started when Jimmy was training for marathons, when he would practice burpees as a means of protecting himself if he were to fall. Eventually, one burpee turned into more, and this led him to pursue and achieve his first Guinness World Record: 30 chest-to-ground burpees in 60 seconds! After that, he went for his second world record of 40 side-to-side (plyometric lateral) pushups in a minute!
Making a Difference in the Fight for Parkinson's
Jimmy's physical goals may have started with a desire to delay or slow the progression of his disease, but his mission has evolved to spread awareness about Parkinson's, raise money for the Michael J Fox Foundation and inspire others. He wants to show others with brain disorders or other illnesses that they “can still thrive and accomplish things that most people thought only 100% healthy people can do”. Through marathons, Spartan races and countless 5k and 10k's, he has raised over $500,000 for Parkinson's research and Team Fox.
When Jimmy isn't training, he can be found spending time with his wife Cherryl and 2 kids, Karina and Mason, or in the kitchen making nutritious (and delicious) meals. He is also an active motivational speaker and a patient council board member of the Michael J Fox Foundation.
His annual 5k race, called Shake It Off, is another way he gets his local community in the Chicago area involved. And last year, Jimmy and his wife Cherryl launched a new social media fundraiser called MOVEmber4PD, to encourage people to get moving in the month of November and raise awareness about Parkinson's. Follow him on Instagram to check out what he’s up to now. Join the movement by signing up and donating to fund high-impact research for Parkinson’s Disease.
Through physical fitness and a never-give-up attitude, Jimmy has proven that anyone can make a difference in the fight against Parkinson’s, or any challenge for that matter! Watch any of Jimmy’s videos, and it’s guaranteed to make you want to MOVE for brain health!
Gilbert, R. American Parkinson’s Disease Association, Lewy Bodies, Dementia, and Parkinson’s – What Does it All Mean?: https://www.apdaparkinson.org/article/understanding-parkinsons-disease-dementia-lewy-bodies/
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DELHI HIGH COURT QUASHES TERMINATION ORDERS OF PILOTS BY AN AIRLINE
Hon’ble Delhi High Court in a recent common judgment passed on June 01, 2021, in “Arjun Ahluwalia Vs. Air India Limited” and other similar forty (40) other petitions involving pilots of Air India Ltd. (‘Airline’), allowed the writ petitions in favour of the employee pilots who sought withdrawal of their resignation letters tendered pre-Covid-19 time, which were accepted by the Airline amid Covid-19 pandemic, even after withdrawal of tendered resignations primarily on ground of severe financial strain and financial impact of global Pandemic Covid-19.
In the leading case, the Petitioner (a Pilot) joined Air India Limited in 2008, as Trainee Pilot, and on completion of training and after several promotions, he was designated as Pilot Commander.
The Petitioner tendered his resignation vide letter dated January 15, 2020 giving six (6) months’ notice, commencing from January 15, 2020, and requested for clearance of all his dues towards salary, flying allowances, etc., credit of contribution into his provident fund account and issuance of a “No objection Certificate‟, issued by Directorate General of Civil Aviation (DGCA). In the resignation letter, Petitioner pointed out that his Bond Period was ending on May 01, 2020 and thus, he be relieved with effect from July 15, 2020 [expiry of six (6) months’ notice period]. Vide letter dated March 18, 2020, on account of compelling personal reasons, Petitioner withdrew his resignation.
Airline vide an e-mail dated March 23, 2020 informed the Petitioner that the withdrawal of his resignation would be examined at a later date. On July 04, 2020, Petitioner sent an e-mail inquiring about the status of the withdrawal of his resignation, but no response was received. Vide order dated August 13, 2020 i.e. seven (7) months after the date of resignation and five (5) months after its withdrawal, Airline accepted the resignation of the Petitioner, overlooking the fact that the resignation stood withdrawn.
A Writ Petition was initiated by the Petitioner before Hon’ble Delhi High Court seeking Court’s direction to the Airline to accept the request for withdrawal and allow the Petitioner to continue in service. Similar reliefs were sought by other forty (40) pilots who approached the Hon’ble Court by filing other writ petitions.
Questions Framed By Hon’ble Delhi High Court
The following questions arose for consideration before the Hon’ble Delhi High Court:
Whether the Petitioners were entitled to withdraw their resignations prior to their acceptance by the Respondent Airlines?
If the answer to the above question was in the affirmative, whether it was open to the Respondent Airlines to accept resignations which stood withdrawn by the Petitioners prior to their acceptance?
Whether financial crisis/distress/crunch of the Respondent Airlines can be a relevant consideration for accepting resignations of the Petitioners in view of the provisions of CAR?
Whether the Petitioners whose terms and conditions of service were governed by Fixed Term Contracts (‘FTC’) can enforce their contracts of employment and/or seek extension/renewal of the
FTCs by invoking the writ jurisdiction of this Court under Article 226 of the Constitution of India?
Hon’ble Delhi High Court’s Decision
The Court observed that the Petitioners in the batch of petitions were Pilots who could be broadly categorized under two heads : (a) Permanent Employees (hereinafter referred to as ‘PEs’) and (b) Fixed Term Contract Employees (hereinafter referred to as “FTCEs‟)
After analyzing the judgements passed by the other courts and Service Regulations of the Airline, the Hon’ble Delhi High Court arrived at the conclusion that a resignation tendered by an employee indicating a prospective or a future date from when the resignation is to take effect, can be withdrawn at any time before it is accepted, in the absence of anything to the contrary in the applicable Rules or terms and conditions of service. It also observed that it may be a different matter where the withdrawal of resignation can be made only with the prior permission of the employer or where the withdrawal needs acceptance underthe given set of Rules, but it found no Rule prescribing any of the two conditions. It also observed that if the resignation is withdrawn prior to its acceptance, it is not open to an employer to accept the resignation, as the same is non-existent and non-est factum in the eyes of law.
The Hon’ble Court held that the Rules applicable to the relevant parties (petitioners) manifest that resignation could only be tendered with a mandatory six (6) months’ notice period and was thus prospective and it cannot be said that offer to resign was in praesenti. Therefore, the inevitable position that emerges is that the petitioners (including the Petitioner) had a right to withdraw the resignations on various dates that they did, prior to their acceptance. Accordingly, it held that the position adopted by the Airline, to the contrary was unacceptable.
The Hon’ble Court also stated that the petitioners (including the Petitioner) were entitled under the Rules to withdraw the resignations and had so withdrawn validly. The next question that arose before the Hon’ble Court was whether it was open to the Airline to accept the resignations. Hon’ble Court answered the said question in the negative, as the moment the resignations were withdrawn during the notice period and prior to their acceptance, they were non-est and non-existent in the eyes of law on the dates the respective decisions were taken to accept them.
Acceptance Of Resignation Before Its Withdrawal
Thus, applying the law propounded by the Hon’ble Supreme Court (of India) in several judgements, the first two questions (A & B) were answered in favour of the petitioners (including the Petitioner). It was held that the petitioners (including the Petitioner) could validly withdraw their resignations before acceptance and during the notice period and that the Airline had no jurisdiction to accept the resignations after the same stood withdrawn.
Question C- Financial Constraints
On the third query (C above), the Court observed that the financial distress in the Airline was not a creation of the Pandemic Covid-19 but existed from the year 2007.Upon enquiry made, it was admitted by the Airline that no other employee of the Airline be it the Cabin Crew, Ground Staff, Administrative Staff, etc., had been retrenched or laid off barring the petitioners (including the Petitioner) and no explanation was there as to why they alone had been discriminated in as much as the financial constraint would equally apply to all classes of employees.
The Hon’ble Court observed that in the garb and guise of accepting resignations, quite clearly Airline had found an easy path to dispense with the services of the petitioners, without following any procedure known to law and without having to bear the monetary consequences and liabilities thereto. If the action of an employer is found to be wrongful in law and the employee is entitled to certain monetary benefits, the employer cannot be heard to set up a defense of financial constraints.
The Hon’ble Court also rejected the ground taken by the Airline on the reasons which motivated most of the Petitioners to tender resignations, being, lucrative job offers in private sectors by holding that when an employee tenders resignation, it is either on account of personal or domestic reasons or for better career prospects. It also held that there are several cases where employees had tendered resignations for any of these reasons and subsequently withdrawn them. Reason for tendering resignation cannot be something that an employer can take a grudge with. The Hon’ble Court condemned the circuitous ways “to ease out” uncomfortable employees. As a model employer the government must conduct itself with high probity and candour with its employees.
Question D- Fixed Term Contract Employees (FTCE)
In response to the fourth query (D above) about FTCEs (pilots), the Hon’ble Court held that they could enforce their contracts of employment and/or seek extension/renewal of the fixed term contract by invoking the writ jurisdiction of Hon’ble Delhi High Court under Article 226 of the Constitution of India. Once the State or an instrumentality of the State is a party of the contract, it has an obligation in law to act fairly, justly and reasonably which is the requirement of Article 14 of the Constitution of India. The Constitution does not envisage or permit unfairness or unreasonableness in State actions in any sphere of its activity. It would be alien to the Constitutional scheme to accept the argument of exclusion of Article 14 in contractual matters.
There is an obvious difference in the contracts between private parties and contracts to which State is a party.
Hon’ble Court And Payment of Back Wages to Permanent Employees and Fixed Term Contract Employees
On the issue of payment of back wages to the petitioners, the Hon’ble Court observed that petitioners are entitled to back wages relying upon Supreme Court’s judgments that the normal rule of “no work no pay” is not applicable to cases wherein an employee is available to work but is kept away by the authorities for no fault of his. This is not a case where the employee remains away from work for his own reasons, although an employer has assigned or could assign work.
The Hon’ble Court thus allowed the writ petitions and Airline was directed to reinstate the petitioners who were PEs (permanent employees) with continuity of service from the date of expiry of the six (6) months’ notice period. Petitioners, who were employed under the fixed term contract (FTC) and the five (5) years period had not expired, were directed to be reinstated and continued in service till the expiry of remaining period of their respective contracts. Petitioners were entitled to back wages commencing from the date of expiry of their respective notice periods of six (6) months and up to the date of reinstatement. The entire exercise including grant of arrears of salary and other emoluments was directed to be carried out and completed by the Airline within a period of six (6) weeks from the date of receipt of copy of the judgement.
Anhad Law’s Perspective
The judgment is significant as the Hon’ble Delhi High Court has held that though it is not for the Court to substitute its own decision for administrative decision taken by the executive even if it is open to two different constructions, however, it is equally well-settled that the decision-making process is open to judicial review on the well-guided principles which are: (a) illegality i.e. the decision maker has not corrected applied the law that regulates the decision making process; (b) decision is vitiated by irrationality tested on the principle of ‘Wednesbury unreasonableness’; and (c) procedural impropriety.
The Wednesbury’s principle is a principle of administrative law where the court sits as a judicial authority over the local authority to see if the local authority has acted in a manner that exceeded its powers, and not as an appellate authority to override a decision of a local authority.1
The Hon’ble Court held that it is entitled to investigate and examine the decision-making process with a view to see whether the concerned Authority has, taken into account irrelevant factors which it ought not to have taken into account or, conversely has failed to take into account or neglected to take into account relevant factors which it ought to have taken. Applying the said principles to the case, the Hon’ble Court held that the impugned decision, when tested on the Wednesbury’s principle clearly reflects that the Airline has taken into consideration the irrelevant factor of financial crunch and has failed to take into consideration the relevant law of resignation while engaging itself in the decision-making process.
The judgment also takes into account the requirement of fairness and uniformity in accepting resignation of employees and to be acted upon before withdrawal of such resignation. The Hon’ble Court further mandated that the Airline to comply with non-discrimination amongst employees and held that financial stress cannot be a ground for termination of services of employees.
Public or Private Employer
It may, however, be mentioned that the aforesaid judgment was passed in case of public employment with the Airline, which is a Government Company. Principles of administrative law or public policy are applicable in the case of government actions and public employment only. A contract of private employment is not similar to public employment and as such in private employment there is no scope of applicability of the principles of administrative law/public law.
Employment in a private sector is governed by the terms and conditions of employment (not being inconsistent with relevant applicable laws), and unless the termination is shown to be violation of the terms and conditions of employment (and/or applicable laws), it cannot be said that the termination is illegal.
Nonetheless, the above judgement of Hon’ble Delhi High Court has once again established the earlier principle that if an employee, who had resigned, but withdrawn his resignation prior to its acceptance by an employer, would continue to remain in service.
–Manishi Pathak, Founding Partner and Ranjan Jha, Partner.
1The Wednesbury principle of unreasonableness or irrationalityhas its genesis in the judgment of ‘Associated Provincial Picture Houses Ltd. Vs. WednesburyCorpn.’, reported in (1947) 2 All ER 680 laid down by Lord Greene whichlays down various basic principle relating to judicial review of administrative or statutory discretion. The principle of “Wednesbury unreasonableness” or irrationality, as one of the grounds for intervention in judicial review, was lucidly summarised as follows:
“…the court is entitled to investigate the action of the local authority with a view of seeing whether it has taken into account matters which it ought not to take into account, or conversely, has refused to take into account or neglected to take into account matters which it ought to take into account. Once that question is answered in favour of the local authority, it may still be possible to say that the local authority, nevertheless, have come to a conclusion so unreasonable that no reasonable authority could ever have come to it. In such a case, again, I think the court can interfere.”
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Manishi Pathak
Designation: Founding Partner
Education: M.Sc (1989) L.L.B. (1992)
Email: manishi@anhadlaw.com
Location: New Delhi, Ahmedabad
Anti-Bribery & Anti-Corruption | Dispute Resolution | Environmental, Social and Governance (ESG) | Employment & Labour | Corporate, Commercial and Regulatory | Government Relations | Mergers & Acquisitions
Manishi Pathak is the Founder and Managing Partner of ANHAD LAW.
Manishi has experience of over three decades. His areas of practice include dispute resolutions, labour and employment, corporate investigations, compliance audit and investigation into non-compliance of anti-bribery and anti-corruption laws, besides advisory and transactional supports on matters involving other corporate and commercial laws.
Manishi is also known for his expertise in the area of mergers and acquisitions/ joint ventures, corporate restructuring and re-organizations besides his government relations work.
He has been appreciated by clients for his hands-on approach and for providing solution-oriented sound legal advice which is commercially and practically tenable. He is also known for offering unique blend of analytical thinking and business strategy, while structuring, negotiating and closing complex commercial transactions and resolution of disputes including mediation and arbitration.
Manishi also has vast experience of delivering advisory support in areas of law, including but not limited to contentious commercial disputes, regulatory compliances (involving exchange control regulations in addition to other regulatory matters), compliance advisory under various corporate and commercial laws, rules etc. (under applicable Central and/or State).
Manishi’s primary area of interest and specialization besides dispute resolution and government relations is Labour and Employment laws. He enjoys a distinguished status and standing in the sphere of Labour and Employment law practice. He is widely recognized as a ‘top ranked specialist’ in this area of practice owing to his deep knowledge and vast experience of dealing with range of matters in the domain of labour and employment laws practice including court litigation and appellate work.
Manishi has retained most top accolades on offer by leading global legal ranking bodies such as Chambers & Partners, Legal 500 etc., in the field of Labour and Employment laws in India. For over last decade, Manishi and he been retained title of ‘Top Ranked’ ‘Leading Practitioner’, ‘Specialist’, owing to established expertise and in-depth knowledge he possesses in the sphere of Labour and Employment laws practice in India.
Manishi is considered to be one of the first legal professionals who identified the scope, ambit and applicability of various central and state specific labour and employment legislations in India, while making foreign and Indian multinational corporations having business presence in India recognize the importance of compliance to various labour and employment laws related legislations in India.
Undisputedly, in the context of Indian scenario, Manishi is regarded as the legal professional who played a pivotal role that lead to recognition and acceptance of ‘labour and employment’ laws as a prominent and established area of practice, amongst other practice areas.
As the practice head, Manishi is actively involved in advising on a wide range of labour laws related queries, preparation and standardization of employment agreements and other agreements such as non-compete and non-solicitation agreement, non-disclosure and confidentiality agreements, HR policies/handbooks/manuals etc., including structuring of ESOPs, closure of businesses, termination/transfer of employees, other termination related issues, trade union related disputes, social security and/or insurance claims, etc. The Firm predominantly represents companies/corporations and their management on employment related projects and litigation.
Manishi also leads members of the firm on matters involving employment audits, whistle-blower investigations, closure of establishments, transfer of business and undertakings, sexual harassment complaints, employer and employee rights and matters involving trade unions. He is also known for his involvement in investigations and/or enquiries concerning employees including in matters of misconduct by employees and/or associated parties.
Prior to founding Anhad Law, Manishi has been the Partner of other renowned law firms of India.
Manishi has considerable experience of representing clients belonging to manufacturing as well as services business, across varied sectors including but not limited to automobiles, aviation, banking, chemicals, commerce, electronics, FMCG, information technology, paper, packaging, pharmaceuticals, ports, real estate, retail and telecommunications, amongst others.
Chambers and Partners lists Manishi in Band 1 for Employment Law and he has been recognised as a leading employment law specialist in India since 2013. They have provided the following comments as well: Manishi Pathak commands ‘great respect in the employment market,’ clients valuing him especially as a ‘very experienced partner who brings a lot of insight to particularly complex employment issues.’ He offers significant expertise in the handling of the employment aspects of M&A transactions and in advising international clients on ensuring that their operations comply with Indian employment laws. Chambers and Partners ranked Manishi as a New Delhi based recognized practitioner in the area of Corporate/M&A for the years 2014 and 2015. He has been ‘Top Ranked’ for 2022 by Chambers and Partners (Asia-Pacific). Chambers Global ranked him as a New Delhi based recognized practitioner in the area of Corporate/M&A for the year 2014 and 2015. Asia Law Profiles 2022 has ranked him as an “Elite Practitioner’ for Labour & Employment Law in India. He was also earlier listed by Asia Law Profiles in 2017, 2019 and 2020. He has been listed in the Who’s Who Legal of Indian practitioners in the field of Labour & Employment law since 2009. Legal 500 has further recognised him amongst India’s leading lawyers for the last several years including 2021.
He has authored several publications on Indian Labour & Employment law for Kluwer Law and Law Business Research and he writes and speaks regularly on a range of subjects, including foreign investment in India and Labour and Employment law.
Some of his prominent publications include “Restrictive Covenants” (India Chapter) by Kluwer Law Publication; “Hiring and retaining Talent” (India Chapter) by Kluwer Law Publication; “Getting The Deal Through (Labour & Employment)”, India Chapter by Law Business Research; Labour and Employment Compliance in India, 9 editions, published by Kluwer Law since 2008 including of 2021.
He has also authored “India Chapter on Employment Law in the Employment Law Review” by Law Business Research since 2010 -15. Manishi also contributed to National Law School Publication (Business Law Review) “An overview of contract labour related laws in India”. He has also contributed to the World Bank Group‘s publication Employing Workers 2021.
Manishi is a member and was an officer of the Employment and Industrial Relations Law Committee of the International Bar Association (IBA). He is also a member of the Delhi High Court Bar Association and Inter Pacific Bar Association (IPBA).
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Fleetwood Mac's Rumours Is Once Again a Top 10 Album in the US
Fleetwood Mac's 'Rumours' Returns to Billboard 200 Top 10 -- 42 Years Later
After a 42-year wait, Fleetwood Mac’s former Billboard 200 No. 1 album Rumours returns to the top 10 this week, as the set jumps 13-7. The album, released in 1977, is basking in the glow of sales and streaming increases spurred on by publicity generated from a viral TikTok video set to the album’s song “Dreams.”
The Billboard 200 chart ranks the most popular albums of the week in the U.S. based on multi-metric consumption as measured in equivalent album units. Units comprise album sales, track equivalent albums (TEA) and streaming equivalent albums (SEA). Each unit equals one album sale, or 10 individual tracks sold from an album, or 3,750 ad-supported or 1,250 paid/subscription on-demand official audio and video streams generated by songs from an album. The new Oct. 24-dated chart (where Rumours returns to the top 10) will be posted in full on Billboard's website on Oct. 20. For all chart news, follow @billboard and @billboardcharts on both Twitter and Instagram.
Rumours earned 33,000 equivalent album units in the U.S. in the week ending Oct. 15 – up 15%, according to Nielsen Music/MRC Data. Of that sum, 23,000 comprise SEA units (up 15%, equating to 30.6 million on-demand streams of the album’s songs, including "Dreams"), a little under 7,000 are in album sales (up 15%) and 4,000 are in TEA units (up 13%).
The TikTok video in question has “Dreams” soundtracking a man in a hoodie (Nathan Apodaca) seemingly being pulled on a skateboard, as he drinks from a bottle of Ocean Spray Cran-Raspberry juice and sings along with Stevie Nicks’ lead vocal. The video became so popular, it moved the band’s own Mick Fleetwood and Nicks to create their own tribute clips.
Rumours spent 31 nonconsecutive weeks at No. 1 on the Billboard 200 in 1977-78 – a record number of weeks atop the list for an album by a duo or group. Rumours was last in the top 10 on the Feb. 18, 1978-dated chart (at No. 10), and last ranked at No. 7 or higher on the Feb. 11, 1978 chart (where it placed at No. 7).
“Dreams” is Fleetwood Mac’s only No. 1 single on the Billboard Hot 100 songs chart – out of 25 chart hits. “Dreams” spent one week at No. 1 on June 18, 1977. The cut is one of four top 10 hits from the Rumours album. The effort also launched the singles “Go Your Own Way” (No. 10), “Don’t Stop” (No. 3) and “You Make Loving Fun” (No. 9).
Posted by Nickslive at Sunday, October 18, 2020
Labels: Fleetwood Mac, Rumours
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Shri Dayal Chandra Soni
Shri Dayal Chandra Soni was born in 1919 in a small town, Salumbar, in the pre-independence state of Mewar (Rajputana), India, which is now southern part of Rajasthan State, India. He was educated at the Vidya Bhawan Institution at Udaipur. Having passed his High School in 1936, he was engaged by the Vidya Bhawan itself as a teacher in its Junior School. But in 1941, he was selected to lead a Gandhian Basic Education School initiated by Vidya Bhawan management. Shri Soni worked with great devotion to make this school a success. In connection with his work, he was fortunate enough to learn about Basic Education from Dr. Zakir Hussain, from Gandhiji himself, and from Vinoba Bhave. In 1954, he had the opportunity of studying the Folk High School System in Denmark.
But unfortunately, in 1955, serious differences arose on moral grounds between him and the Vidya Bhawan management, with the result that he could no longer work in the Vidya Bhawan or its Basic School. Nor did he join any other educational institution and somehow managed himself and his family by tuition, typing, and authorship. Ultimately, in 1962, he become a Flour-Miller and sustained himself and his family.
However, in 1969, he was engaged by Vidya Bhawan’s new sister institution (Seva Mandir) for promoting literacy in the adjoining rural areas. Then in 1975, he was engaged as the representative of the World Literacy of Canada (WLC), Toronto, to look after the adult education work of a number of Indian institutions funded by WLC. This engagement continued for nearly five years. Then in 1988, he was again employed by Seva Mandir to look after its Local Culture Unit. But at the age of 75, he retired from this job in 1994.
One book written by him on Non-formal Education (in Hindi) has been given the Madan Mohan Malviya award by the Government of Uttar Pradesh in 1992. He was given “Tagore Award” by Indian Adult Education Association in 2002 for his work related to adult education particularly for propagating the thought that adult education should be given in local language.
Till his last breath on 15th, March 2008, Shri Soni continued writing essays and books on educational reconstruction. Nearly 400 articles and 25 books authored by him have been published
This site aims to provide more and more essays written by him for the benefit of users.
(The word “Shri” used here before the name denotes respect and may be considered similar to Mr. in English.)


Land Policy and Urban Development in Latin America
Graduate Student Fellowship
April 24, 2017 | 11:59PM
Apply / Aplicar
Guidelines / Guía
The Program on Latin America and the Caribbean (LAC) of the Lincoln Institute of Land Policy invites applications for its 2017 Master’s and Doctoral thesis fellowships. Fellowships will be awarded in the amounts of $5,000 for Master’s theses and $10,000 for Doctoral theses to students in Latin and North American universities who are in the mid to final stages of their thesis work. The fellowships are part of LAC’s initiative to identify and support the development of graduate students and young scholars working on land and urban policy issues that align with the Lincoln Institute’s mission and work in Latin America. In addition to funds to undertake their thesis work, fellowship recipients will also be given priority placement in future LAC distance education and professional development courses organized in Latin America. Students may also be invited to present their work in one or more LAC-sponsored research seminars and networking events with senior scholars from Latin America and the Caribbean.
English version of application form
Related files:
Guía 2017 (en español)
Guidelines 2017 (in English)