Neighbor Rosicky and the Death of the Hired Man Essay

Neighbor Rosicky and the Death of the Hired Man - Essay Example In Neighbor Rosicky, the story highlights the situation of Anton Rosicky who has attained vital information from a doctor. Doctor Burleigh has informed Anton that his heart is ailing (Stout 75). In turn, Anton has to keep off from strenuous work. Rosicky buys candy and fabric for his wife whereby his wife recalls Anton’s consistent love for her. Rosicky informs his wife of the same situation whereby he retreats into a reflection about his former life. This pertains to his integration in the American life. In addition, it includes his struggles in London. The last part of the story entails his reflection about his family’s future life. In the Death of the Hired Man, the poem entails arguments between Warren and Mary (Sanders 39). Warren seems to be bitter over his servant who is known as Silas. Silas was a servant who abandoned his duties at the master’s time of need. In the poem, he is back from his travels. Warren is skeptical and bitter about the idea of giving Silas a second chance. His wife pleads with him to consider the same. The poem ends with Silas death. The basic difference between the two works concerns with the fact that they are of different genres. To begin with, Neighbor Rosicky is a short story. On the other hand, the Death of the Hired Man is a poem. ...This is because readers anticipate actions that significantly relate to him. This is exemplified through his struggles at wage earning â€Å"†¦to be a wage earner, a slave all your life, to have nothing, to be nothing.† On the other hand, the Death of the Hired Man is poem with an obscure protagonist because three characters are contending for the same. In terms of Silas, he is an ever-present character that escapes into a foreign land (Sanders 40). He also does an outrageous thing of leaving his work for the town. On the other hand, Warren is a character that readers anticipate his actions as pertains to the fate of Silas. Therefore, he is in substantial control of the same. Mary is principal in influencing his husband’s decision. She pleads with him â€Å"be kind.† It is vital to note that the works share interesting similarities. To begin with, both of the principal characters engage in self-introspection. This is in spite of the fact that Silas introspection is less profound. Silas situation highlights through his actions. Silas’ reflection is intense in a subservient way because it makes a reader ponder over his last life’s actions. In his life, he had spent the same on betraying his master and those who were close to him. There seems to be something strong that drives Silas into going back to Warren’s home. In display of Silas introspection Mary says, â€Å"Silas declares you’ll have to get him back.† In this sense, Silas has shown that he pondered over the same. It is a manifestation of reconsideration. In addition, both of the works share an interesting chronology of events. The flash backs contribute to the prominent prose of the same. In Neighbor Rosicky, Anton attains information about his health. He proceeds to buy a

The Culture of Poland Research Paper Example | Topics and Well Written Essays - 1500 words - 1

The Culture of Poland - Research Paper Example This research will begin with the statement that Poland has a total population of thirty-nine million people and is richly endowed with natural resources. In addition to the inhabitants of the country is good entrepreneurs, Poland has attracted numerous foreign investors, thereby making its economy dynamic. The country is a member of the European Union and is the sixth biggest country in the union. The main sectors supporting the economy include information technology, automotive electronics, food processing, tourism, and the banking. According to Skarzynska, the Polish people have a unique business culture where they are ambitious individuals who are hard negotiators and always eager to do business. They have also acquired western methods of business management and are bureaucratic. To successfully invest in a country and market your products, it is important to understand the cultural environment. Language is an important aspect of the people’s culture and is critical when c ommunicating with others. Comprehending the language of the people in a country is important when carrying out business with the inhabitants of the country or in daily general interactions. Poland is made up of four main ethnic groups: Poles, Germans, Belarusians, and Ukrainians. The Poles are the majority making up 96.7 percent of the total population according to a census carried out in 2002; Germans are 0.4 percent; Ukrainians and Belarusian are 0.1 percent each.

Debussy and Impressionism Research Paper Example | Topics and Well Written Essays - 2500 words

Debussy and Impressionism - Research Paper Example The paper "Debussy and Impressionism" explores Debussy's art and his influence of impressionism movement. Yet in a letter to his friend Arthur Hartmann he writes, â€Å"I became lost in my impressions, dazed in my emotions†. In denying the influence of impressionism on his work Debussy may have been reacting to early negative critical reviews of the impressionist movement in general. Today, perhaps, he might have been pleased to be included. Using two works, Monet’s Impression, Sunrise and Debussy’s Printemps, this essay explores the relationship between the two and offers evidence to support the notion that Debussy, despite protestations to the contrary, was indeed an impressionist. The Impressionism period covers approximately two decades from the late 1860s through the 1880s. The movement, originating in France in the last quarter of the nineteenth century, developed in response to the French Academy of Fine Arts and its narrow, overbearing and restrictive rul es as to what did or did not constitute art. A group of painters who became known as the Impressionists [not a compliment in those days] felt strongly about securing independence from these restrictive standards and the dictates of its annual official art exhibition, The Salon. The term impressionist was first used by French art critic Louis Leroy in 1874 in response to Monet's painting Impression, that will play an intrinsic role in the comparisons between Debussy as an impressionist and the artistic impressionists of the time.

Symbolism in Hardys Essay Example for Free

Symbolism in Hardys Essay Symbolism in Hardys Far from the madding crowd Hardy uses striking symbolism in the novel Far from the madding crowd to serve his purposes and attain the desired effects on the reader. The memorable descriptions of the great barn, the sword play and the storm-are all enriched with eloquent symbolism. It makes the events vivid before us and broadens the scope of the novel. In the opening chapters, Gabriel spies on Bathsheba ridiculously from behind a hedge, commenting on her vanity. He beholds Bathsheba though a hole, tending her aunts cows, in a birds eye view. From the loopholes of his hut, he watches her engaging in tomboyish antics on her horse. All these symbolize Gabriels limited view point and his candid nature. In chapter 2 ,, Hardy presents a magnificent description of Norcombe hill. The stately progress of the earth is contrasted to oaks special power of quiet energy. The innocent and helpless stirrings of the new-born lamb and the movements of the stars and the earth are contrasted to symbolize the frailty of human existence. In chapter 5, The landscape of Norcombe Hill seems symbolize Gabriels utter despair. The moon takes the form of an attenuated skeleton and the pool shimmers like ahead mans eye-nature seems to intertwine with Gabriels despair. Against the colorless background of the river and the wall. Fanny is contrasted as a mere shade upon the earth. This symbolizes her nullity and despair. Hardy also uses the framing device to symbolize Fannys weakness. She gazes up to converse with Troy framed in a window of his barracks . The white color of the snow mixing with the sky symbolizes the obsession of Boldwoods passion . The queer preternatural inversion of light and shade reflects the absurdity of his intense emotional state. The sheep-shearing scene at the barn abounds in rich symbolism. The shearing operations that have not been mutilated for long years are contrasted to the adapted to changes coming to the lives of the main characters of the novel. The detailed descriptions of the activities done in the great barn for each sheep symbolizes the declining prospects of Oak, the rising hopes of Boldwoods mind and the comments made by the rustics -all basing on the same lady. There is also sexual symbolism in this same chapter. The appalled ewe is subdued by Oak and Bathsheba regards the ewes sheared pink skin resembles a lady who blushes at the insult . the ewe emerging from the its fleece is compared to the Goddess of love which symbolizes the sexual intensity of Oaks violent passion. Gabriel, piqued by Bathshebas growing intimacy with Boldwood, injures a sheep in the groin-the entire scene symbolizes Oaks harmful sexual impulses toward Bathsheba. Troys spur entangles with Bathshebas dress-it symbolizes the trap of flattery which would be prepared by Troy for her. The spur is the symbol of sex and the dress of Bathsheba is a symbol of femininity -the male aggressive masculinity has trapped femininity. However, the scene of the sword play contains the greatest symbolism in the novel. The hollow in which the sword play is performed evokes the sexual potential of the relationship between Troy and Bathsheba. The setting is described with rich feminine imagery that sets up the erotic tone of the entire tone of the entire scene while Bathsheba herself is passionately excited . Time and place are made clear at once and so is Bathshebas desire for male domination . The sword is used here as a symbol of male virility . At different points ,Hardy uses striking imagery to link man and sword -Troy raises the sword amid the fading sunlight , which gleamed a sort of greeting, like a living thing Troy is methodical and controlled ,the whole atmosphere is turned meteoric and charged . Troy demonstrates the murderous and blood-thirsty cuts of which the sword is capable . Then he splits a caterpillar upon her bosom which glisten towards her bosom and ,seemingly entered it . Troy wins and Bathsheba is quite overcome having her passions spent . Troy takes off her lock of hair as a trophy. Troy departs in a flash , like a brand . The simile symbolizes the harmful nature of the passion he has aroused. The storm scene in chapter 36-38 contain rich symbolism. The flashes symbolize the blinding truth of Bathshebas predicament and her womanish folly. But the relation between her and Oak strengthens as the thatch begins to conceals the Ricks. And when the storm comes, it is described with extended imagery ,the mailed army of lightning springs like a serpent , with the shout of a fiend . Hardy uses such imagery to convey the forces of nature hostile to human beings . The scene of chapter 44 is significant as it indicates Bathshebas return to the same hollow where sword-play was performed by Troy. The aforesaid hollow is now turned into a malignant swamp. The swamp is the symbol of utter despair into which Bathsheba has fallen . The symbolism goes far deeper as Bathsheba had seen the place before when she was captivated by Troy at the sword play. At that time , the ferns were soft , feathery arms caressing her feet but now they are withering fast and the hollow is a nursery of pestilences . The two different states of the hollow reflects the two opposing states of mind and suggests the outcome of marriage with Troy . Now she has understood the implications of her marriage and she herself and Nature are fused as the leaves rush away in the breeze. This symbolizes Nature as a stark force and implies that the parallel between Nature and human mood should not be pursued by man.

Energy Alternatives: Oil Essay -- Iraq Oil War Energy Essays Papers

Energy Alternatives: Oil Every day the world burns more that 80 million barrels of oil. By 2016, estimates believe that oil consumption will rise to around 100 millions barrels a day. (Oil Facts) The United States was responsible for 25% of the world oil consumption in 2002, and those numbers are rising. (Oil Demand) As demands increase and the supplies of oil continue a rapid depletion, large political powers in the US struggle to keep their heads afloat. Many conspiracy theories have dabbled in the pool of scandal within the Whitehouse’s knowledge of September 11 before it happened, and George W. Bush’s master plan to wage a â€Å"War on Terror†, with a backdrop of draining the last of the oil supplies from the mid-East. Every conspiracy theory needs to be taken with a grain of salt, but it is important to remember our past. It was only until long after the Vietnam war that people were told of the pre-knowledge of utter lack of any possibility for them to win the war, yet officials still pressured our armies into Vietnam until near extinction. In 50 years, we will all know the real deal behind September 11th and George Bush’s strong motives to pursue the War on Terror (even when the rest of the world advices against it.) The US is a country with one of the most unhealthiest addictions possible: oil. Just as a heroine addict who is running low on fixes, the US is running low on supplies, and drastic, unwise measures are being taken in order to sustain this addiction for just a bit longer. This enters the Enron-Cheney-Taliban Connection, which has startling information that aligns a bit of history prior to September 11. The mother of all oil support and scandal rests with Enron, however, witho... ...ependency on the mid-East, bring our troops home, and make for a better future for our children. â€Å"Is the White House covering up that it was molding foreign policy as well as energy policy to suit Enron? Did the Bush Administration know that Enron's collapse was coming as early as August? If any of these are true, the largest bankruptcy in American history may well connect with the greatest political scandal in American history.† (Callari) Bibliographies: Callari. The Enron-Cheney-Taliban Connection. 28 Feb 2002. 14 Feb 2007. Albion Monitor. Oil Demand. 2006. 14 Feb. 2007. Interesting Oil Industry Statistics. Oil: Facts Behind the Fiction. 25 May 2006. 14 Feb. 2007. BBC News.

Chaucers Canterbury Tales - Chaunticleer :: Chaucer Canterbury Tales

Canterbury Tales - Chaunticleer In the book Canterbury Tales, Geoffrey Chaucer, gives us a stunning tale about a rooster named Chaunticleer. Chaunticleer, who is the King of his domain in his farmland kingdom. Like a King, he quotes passages from intellectuals, dreams vivid dreams, has a libido that runs like a bat out of hell, and is described as a very elegant looking Rooster. He has every characteristic of a person belonging to the upper class. Chaucer's hidden meanings and ideas make us think that the story is about roosters and farm animals, but in reality he is making the Aristocracy of his time period the subject of his mockery by making the reader realize how clueless the Aristocracy can be to the way things are in the real World. Chaucer describes Chaunticleer in many different ways. One of them is his language. Chaunticleer's language is that of a scholar. He quotes many different scriptures in a conversation with Pertelote, such as, Saint Kenelm, Daniel and Joseph (from the bible), and Croesus. From eac h author he tells a story about an individual who had a vision in a dream and the dream came true. He may have been making all the stories up in order to win the argument with Pertelote, but, this seems unlikely because he does not take heed to his own advice and stay away from the fox that encounters him later. He is educated enough to know these supposed quotations but not intelligent enough to understand the real meaning of them. It is if he simply brings because they help him win the argument with his spouse and not because he actually believes what they say. Chaucer is using the idea that the Aristocracy has schooling throughout their childhood, but it is only done to have seemingly important but empty conversations. His physical appearance is also described with such beautiful passion that it makes us think Chaunticleer is heaven on earth. "His comb was redder than fine coral, and crenellated like a castle wall; his bill was black and shone like jet; his legs and toes were lik e azure; his nails whiter than lily; and his color like the burnished gold." Chaucer describes Chaunticleer as the quintessential Cock, so perfect that his description is no longer believable when we realize he is describing a Rooster. Chaucer is setting up Chaunticleer to be as regal and grandiose as a King.

Proprietary Estoppel Essay

â€Å"In Thorner –v- Major, the House of Lords confirmed that a claimant seeking to establish a proprietary estoppel must prove three things: (1) that the defendant’s assurances or conduct in relation to identified property were sufficiently clear and unambiguous in all the circumstances, (2) to lead the claimant reasonably to rely on those assurances or conduct; (3) by acting significantly to his detriment, so that it would be unconscionable for the defendant to deny him any remedy.† (Per Hayton and Mitchell: ‘Commentary and cases on the law of Trust and Equitable Remedies’, 13th edition, Sweet and Maxwell, page 78) Critically analyse and evaluate this statement in light of recent developments in the law of proprietary estoppel. Despite the lack of a definitive formulation, it is widely accepted that the elements of assurance, reliance and detriment must be present in order to found a claim of proprietary estoppel . The doctrine has however been widely criticised for being too flexible and uncertain. The main cause of this uncertainty is the lack of clarity surrounding the role of unconscionability. It has been stated that unconscionability is â€Å"at the heart of the doctrine,† and yet there is â€Å"little guidance as to what it means, little explanation of why it is at the centre and thus virtually no consideration of the role it might play in providing both a justification for, and a limitation on, successful estoppels† . Commentators have largely agreed that there is a â€Å"need to develop clear parameters for the operation of the doctrine, else it really will be a discretionary panacea for all ills whose application is unpredictable and uncertain. Prior to Thorner v Major [2009] and Cobbe v Yeoman’s Row Management Ltd [2008] it had been 142 years since a case of proprietary estoppel had reached the House of Lords. Therefore it was hoped that these cases would give the judiciary a long awaited opportunity to clarify the doctrine. In Cobbe Lord Walker stated that â€Å"Equitable estoppel†¦is not a sort of joker or wild card to be used whenever the court disapproves of the conduct of a litigant who seems to have the law on his side. Flexible though it is, the doctrine must be formulated and applied in a disciplined and principled way.† The House of Lords appeared determined to address the criticisms and it was hoped that they were about to define and clarify the doctrine, especially the role of unconscionability. Lord Scott, who gave the leading judgement, stated that unconscionability alone is never enough to found a claim of proprietary estoppel. â€Å"To treat a ‘proprietary estoppel equity’ as requiring neither a proprietary claim by the claimant nor an estoppel against the defendant but simply unconscionable behaviour is, in my respectful opinion, a recipe for confusion†. Lord Walker addressed the uncertainty over whether unconscionability is a separate element, by stating that â€Å"unconscionability†¦ does in my opinion play a very important part in the doctrine of equitable estoppel, in unifying and confirming, as it were, the other elements. If the other elements appear to be present but the result does not shock the conscience of the court, the analysis needs to be looked at again† . These emphatic statements confirmed that unconscionability alone is insufficient to give rise to a claim of proprietary estoppel and that the traditional elements must always be present. It is suggested however that these pronouncements did very little in practice to define or clarify the concept. The modern approach to proprietary estoppel which began with Taylor Fashions Ltd v Liverpool Victoria Trustees Co Ltd [1982] adopted a â€Å"broad test of whether in the circumstances the conduct complained of is unconscionable without the necessity of forcing those incumbrances into a Procrustean bed constructed from some unalterable criteria.† Despite this statement the judgement in Taylor Fashions did not rely on unconscionability alone. The court required the three traditional elements to be present, albeit adopting a new claimant centred approach to establishing them. Therefore the statements in Cobbe regarding unconscionability are uncontroversial and do not significantly alter its position within the doctrine. The judgement in Cobbe was regarded as a severe curtailment of the doctrine and was believed to have greatly narrowed the scope of its operation. It was even thought that it had led to the ‘the death of proprietary estoppel’ This was not due to the outcome of the case, but due to the controversial reasoning behind this decision. Lord Scott attempted to rein in the doctrine by focusing on the traditional elements of proprietary estoppel and restricting the doctrine via their operation. He focused on the assurance or representation element, which requires that the claimant must have been led to believe that he has or he will acquire an interest in the defendant’s land. He stated that the required assurance was of a ‘certain interest’ and this meant that the claimant must specify the interest in the property he believed he had or would have. Cobbe dealt with a case of proprietary estoppel in a commercial context. Therefore Mr Cobbe’s â€Å"was not an expectation that he would, if the planning application succeeded, become entitled to â€Å"a certain interest in land† but an expectation â€Å"of further negotiations leading, as he hoped and expected, to a formal contract† . Lord Scott stated that this was not â€Å"the sort of expectation of ‘a certain interest in land’ that Oliver J in the Taylors Fashions case or Lord Kingsdown in Ramsden v Dyson had in mind† and so the claim failed. This requirement for a specific assurance narrowed the scope of operation of the doctrine and was inconsistent with previous Court of Appeal decisions such as Gillett v Holt and Jennings v Rice where a claimant had an expectation of a future interest in land. Lord Walker further restricted the doctrine by stating that the claimant must believe â€Å"that the assurance on which he or she relied was binding and irrevocable†. Therefore the claimant must not only believe that the landowner has made a promise, but also believe that the promise is legally binding. He made it clear that context was important. â€Å"In the domestic or family context, the typical claimant is not a business person and is not receiving legal advice†¦The focus is not on intangible legal rights but on the tangible property which he or she expects to get.† As the parties involved in Cobbe were â€Å"persons experienced in the property world, both parties knew that there was no legally binding contract, and that either was therefore free to discontinue the negotiations without legal liability†¦the fact is that he ran a commercial risk, with his eyes open† This restriction is also inconsistent with Gillett v Holt which â€Å"explicitly addressed, and rejected, the notion that the revocability of wills prevents a promise to make a will forming the basis of a proprietary estoppel claim.† Surprisingly it was Lord Walker who gave the leading judgement in that case and acknowledged here that â€Å"It may possibly be that some of the domestic cases might have been decided differently if the nature of the claimant’s belief had been an issue vigorously investigated in cross-examination.† Thus casting doubt on previous court of appeal authorities relating to testamentary promises . The reasoning in Cobbe left the doctrine in an uncertain position and â€Å"If taken literally, this reformulation would have curtailed the reach of estoppel, and perhaps that was the point†. Thorner v Major gave the House of Lords a chance to address these uncertainties and a further opportunity to clarify the doctrine definitively via the role of unconscionability. From the beginning the Lords made it clear that the decision in Cobbe had not â€Å"severely curtailed, or even virtually extinguished, the doctrine of proprietary estoppel (a rather apocalyptic view that has been suggested by some commentators).† Thorner dealt with proprietary estoppel in the domestic context. One cousin had worked unpaid on the other’s farm for nearly 30 years on the understanding that he would inherit the farm on his cousin’s death. The cousin died intestate and the claim of proprietary estoppel had been rejected by the Court of Appeal. One reason given for this failure was that the extent of the farm had fluctuated in the preceding years and so the interest the claimant expected to receive was not a sufficiently ‘certain interest’ as required following Cobbe. The Lords in Thorner made it clear that â€Å"the reasoning in Cobbe’s case†¦was directed to the unusual facts of that case† and that in Cobbe â€Å"there was no doubt about the physical identity of the property. However, there was total uncertainty as to the†¦property interest†¦In this case†¦there is†¦no doubt as to what was the subject of the assurance, namely the farm as it existed from time to time. Accordingly, the nature of the interest to be received by David was clear: it was the farm as it existed on Peter’s death. They confirmed that the assurances â€Å"should relate to identified property owned (or, perhaps, about to be owned) by the defendant.† and that â€Å"It would represent a regrettable and substantial emasculation of the beneficial principle of proprietary estoppel if it were artificially fettered so as to require the precise extent of the property the subject of the alleged estoppel to be strictly defined in every case.† Context is vital, whereas a specific certainty may be required in a commercial situation, this will not necessarily be required in a domestic context. The Court of Appeal had also required that the nature of the assurance be â€Å"clear and unequivocal† . This test for clarity of assurance was that required in promissory estoppel, and may have been adopted here due to the conflation of the two forms of estoppel by Lord Scott in Cobbe . The parties in Thorner were â€Å"taciturn and undemonstrative men† and the assurances mainly consisted of â€Å"oblique remarks† and therefore it was held that these assurances lacked the requisite certainty. The House of Lords loosened this restriction stating that â€Å"I would prefer to say †¦that to establish a proprietary estoppel the relevant assurance must be clear enough. What amounts to sufficient clarity, in a case of this sort, is hugely dependent on context† . As â€Å"the relationship between Peter and David was familial and personal, and neither of them†¦had much commercial experience†¦Peter made what were, in the circumstances, clear and unambiguous assurances that he would leave his farm to David, and David reasonably relied on, and reasonably acted to his detriment on the basis of, those assurances, over a long period.† The House of Lords had made it abundantly clear once again that everything is dependent on context. In a domestic context such as Thorner an oblique assurance may be ‘clear enough’ even though a commercial case such as in Cobbe may require a much more specific assurance. Lord Walker also rejected Lord Scott’s characterisation of estoppel â€Å"I have some difficulty with Lord Scott’s observation†¦that proprietary estoppel is a sub-species of promissory estoppel.† The House of Lord’s in Thorner also clarified that the correct approach for landowner’s intention was an objective test and that it was â€Å"enough that the meaning he conveyed would reasonably have been understood as intended to be taken seriously as an assurance which could be relied upon†¦It is not necessary that Peter should have known or foreseen the particular act of reliance†. The House of Lords allowed the proprietary estoppel claim to succeed even tho ugh there was no evidence that the claimant believed that the assurance was legally binding, therefore also rejecting Lord Walker’s restriction in Cobbe. Thorner had maintained a flexible approach to proprietary estoppel making it clear that everything was â€Å"hugely dependent on context†, re-affirming the holistic approach found in Gillett that â€Å"in the end the court must look at the matter in the round.† Lord Neuberger stated that â€Å"it appears to me unlikely in the extreme that Lord Scott was intending impliedly to disapprove any aspect of the reasoning or decision of the Court of Appeal in Gillett’s case† Thorner effectively placed the doctrine back in the position it stood before Cobbe. It was said that the decision in Thorner had â€Å"brought proprietary estoppel back from the brink. The apocalypse†¦has been averted and proprietary estoppel can continue to function as an independent source of rights. It can thus perform its vital role as a broad and flexible doctrine.† Thorner has clarified some of the uncertainties surrounding the traditional elements of proprietary estoppel that had been raised in Cobbe and followed in the Court of Appeal. It returned the formulation to a flexible and broad definition requiring ‘identifiable property’ that the assurance must be â€Å"in the circumstances, clear and unambiguous† and that the assurance must â€Å"reasonably have been understood as intended to be taken seriously as an assurance which could be relied upon. Thorner did not however say anything regarding role of unconscionability, only affirming the uncontroversial position taken by Cobbe, whilst confirming the flexibility of the doctrine. â€Å"Concentrating on the perceived morality of the parties’ behaviour can lead to an unacceptable degree of uncertainty of outcome, and hence I welcome the decision in Cobbe’s case†¦However, it is equally true that focussing on technicalities can lead to a degree of strictness inconsistent with the fundamental aims of equity† . Some commentators believe that this was an opportunity missed as â€Å"Lord Scott may have chosen the wrong train to ride in Yeoman’s Row, but it is not clear that he chose the wrong destination† Defining ‘unconscionability’ is a difficult task and commentators have their own competing theories. Dixon believes that â€Å"an estoppel is made out when a landowner makes a ‘double assurance’ – an assurance that the claimant will have some right over the representor’s land†¦combined with an assurance that the right will ensue even if the formalities necessary to convey that right are not complied with†¦Unconscionability exists when a ‘formality assurance’ is withdrawn after detrimental reliance † Balen and Knowles believe that â€Å"this â€Å"extra ingredient†, for so long described as â€Å"unconscionability†, requires the court to ask whether the basis, or condition, on which the claimant incurred her detriment has failed.† There is no consensus as to how unconscionability should be defined only that it should. It may be that the judiciary have missed an opportunity to clarify the doctrine or it could be that they have no desire to â€Å"define unconscionability and thereby limit the application of the doctrine†¦Uncertainty can be a benefit as well as a burden, and while unconscionability of itself cannot generate an estoppel, the claim can be denied despite t he presence of an assurance, reliance and detriment by judicious deployment of the ‘unconscionability’ card†.