title: Diving chamber

text: Life support systems for saturation systems can be fairly complex, as the occupants must remain under pressure continuously for several day to weeks. Oxygen content of the chamber gas is constantly monitored and fresh oxygen added when necessary to maintain the nominal value. Chamber gas may be simply vented and flushed if it is air, but helium mixtures are expensive and over long periods very large volumes would be needed, so the chamber gas of a saturation system is recycled by passing it through a carbon dioxide scrubber and other filters to remove odours and excess moisture.


title: Diving chamber

text: Multiplace chambers that may be used for treatment usually contain a built-in breathing system (BIBS) for supply of breathing gas different from the pressurisation gas, and closed bells contain an analogous system to supply gas to the divers' umbilicals. Chambers with BIBS will generally have an oxygen monitor. BIBS are also used as an emergency breathing gas supply if the chamber gas is contaminated.


title: Diving chamber

text: Sanitation systems for washing and waste removal are required. Discharge is simple because of the pressure gradient, but must be controlled to avoid undesired chamber pressure loss or fluctuations. Catering is generally provided by preparing the food and drink outside and transferring it into the chamber through the stores lock, which is also used to transfer used utensils, laundry and other supplies.


title: Diving chamber

text: Non-portable chambers are generally constructed from steel, as it is inexpensive, strong and fire resistant. Portable chambers have been constructed from steel, aluminium alloy, and fibre reinforced composites. In some cases the composite material structure is flexible when depressurised.


title: Diving chamber

text: Details will vary depending on the application. A generalised sequence for a stand-alone chamber is described.


title: Diving chamber

text: The operator of a commercial diving decompression chamber is generally called a Chamber operator, and the operator of a saturation system is called a life support technician (LST).


title: Diving chamber

text: A large range of working pressures are used, depending on the application of the chamber. Hyperbaric oxygen therapy is usually done at pressures not exceeding 18msw, or an absolute internal pressure of 2.8 bar.


title: Diving chamber

text: Decompression chambers are usually rated for depths similar to the depths that the divers will encounter during planned operations. Chambers using air as the chamber atmosphere are frequently rated to depths in the range of 50 to 90 msw, and chambers, closed bells and other components of saturation systems must be rated for at least the planned operational depth. The US Navy has Heliox saturation decompression schedules for depths up to 480 msw (1600 fsw). Experimental chambers may be rated for deeper depths. An experimental dive has been done to 701 msw (2300 fsw), so at least one chamber has been rated to at least this depth.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: Kosaka, the creator of "PPAP", said in an interview that he came up with the song sitting in his house. He was listening to the tune when he picked up a pen to start writing. He thought about his background of being from Japan's biggest apple-producing region (Aomori Prefecture) as he also realized that he had an open can of pineapple slices on the table.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: The song is written in the key of C♯ minor with a common time tempo of 136 beats per minute. Pikotaro's vocals span from F♯ to C♯ in the song.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: The song originated as a music video released on YouTube on 25 August 2016. In the video, Pikotaro, dressed in a yellow snake/leopard animal print costume, dances around, and then sings English lyrics like "I have a pen, I have a apple. Uh! Apple pen" while making the gestures of holding the named items and combining them. The video's expense was about 100,000 yen.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: On 26 September, Pikotaro released a video on how to do the dance and the gestures. On 27 October, Pikotaro posted a "long version" of the music video.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: On 17 November, Pikotaro made an appearance on the Japanese edition of "Sesame Street", where he joined Elmo and Cookie Monster in singing their version of the song titled "CBCC (Cookie-Butter-Choco-Cookie)".


title: PPAP (Pen-Pineapple-Apple-Pen)

text: Pikotaro has since revisited the compounding-words concept of PPAP in later music videos, such as the musically similar "Beetle Booon But Bean in Bottle (BBBBB)".


title: PPAP (Pen-Pineapple-Apple-Pen)

text: "PPAP", alongside three other works by Pikotaro, was released to digital storefronts through Avex Music Creative on 7 October 2016. An instrumental version of the song was made available on 12 October 2016.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: The video accumulated about 1 million hits in its first month of play. Kosaka remarked it was mostly popular among Japanese students. On 27 September 2016, Canadian pop singer Justin Bieber shared the video on Twitter, captioning it as his "favorite video on the Internet". The video had since gone viral, averaging over 1.5 million hits a day, and being touted as the new "Gangnam Style" by various newspapers and online media. It has spawned many videos from people doing their own versions. On the YouTube music video charts it reached number 1, and stayed there for three weeks in a row. A PPAP Cafe in Tokyo was open for 20 days starting from 1 November 2016.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: In response to the COVID-19 pandemic, Pikotaro uploaded a remix of the song on 4 April 2020, titled "PPAP-2020." In the remix, Pikotaro pretends to combine his hands with soap, and repeats "Wash! Wash! Wash! Wash!" while pretending to wash his hands. In the end, he tells the viewers to "Pray for People And Peace."


title: PPAP (Pen-Pineapple-Apple-Pen)

text: In "Mashin Sentai Kiramager, THE MOVIE: B-Bop Dream", Muryo Hakataminami, portrayed by Daimaou Kosaka sings PPAP to wake the Kiramagers.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: The song debuted at number four on the "Billboard" Japan Hot 100 dated 22 October 2016. The following week it climbed to number three and the week after that it peaked at number two. After dropping to number three, it topped the chart for the 14 November edition.


title: PPAP (Pen-Pineapple-Apple-Pen)

text: The song debuted on the "Billboard" Hot 100 in the United States at number 77, and at 45 seconds in length, becoming the shortest song to chart in its history at the time. The previous shortest song was "Little Boxes" by The Womenfolk, which reached number 83 in 1964 and was 1 minute and 2 seconds in length. The fact was recognized by Guinness World Records. The song has since reappeared twice more, at number 82 for the week of 26 November, and 93 the week of 3 December.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014), is a landmark decision in United States corporate law by the United States Supreme Court allowing privately held for-profit corporations to be exempt from a regulation its owners religiously object to, if there is a less restrictive means of furthering the law's interest, according to the provisions of the Religious Freedom Restoration Act of 1993. It is the first time that the Court has recognized a for-profit corporation's claim of religious belief, but it is limited to privately held corporations. The decision does not address whether such corporations are protected by the free exercise of religion clause of the First Amendment of the Constitution.


title: Burwell v. Hobby Lobby Stores, Inc.

text: For such companies, the Court's majority directly struck down the contraceptive mandate, a regulation adopted by the United States Department of Health and Human Services (HHS) under the Affordable Care Act (ACA) requiring employers to cover certain contraceptives for their female employees, by a 5–4 vote. The court said that the mandate was not the least restrictive way to ensure access to contraceptive care, noting that a less restrictive alternative was being provided for religious non-profits, until the Court issued an injunction 3 days later, effectively ending said alternative, replacing it with a government-sponsored alternative for any female employees of privately held corporations that do not wish to provide birth control. The ruling is considered to be part of the political controversy regarding the Affordable Care Act in the United States.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The United States Supreme Court ruled in "Employment Division v. Smith" (1990) that a person may not defy "neutral laws of general applicability" even as an expression of religious belief. "To permit this," wrote Justice Scalia, citing the 1878 "Reynolds v. United States" decision, "would make the professed doctrines of religious belief superior to the law of the land, and in effect to permit every citizen to become a law unto himself. " He wrote that generally applicable laws do not have to meet the standard of strict scrutiny, because such a requirement would create "a private right to ignore generally applicable laws". Strict scrutiny would require a law to be the least restrictive means of furthering a compelling government interest.


title: Burwell v. Hobby Lobby Stores, Inc.

text: In 1993, the US Congress responded by passing the Religious Freedom Restoration Act (RFRA), requiring strict scrutiny when a neutral law of general applicability "substantially burden[s] a person's exercise of religion". The RFRA was amended in 2000 by the Religious Land Use and Institutionalized Persons Act (RLUIPA) to redefine "exercise of religion" as any exercise of religion, "whether or not compelled by, or central to, a system of religious belief", which is to be "construed in favor of a broad protection of religious exercise, to the maximum extent permitted by the terms of this chapter and the Constitution". The Supreme Court upheld the constitutionality of the RFRA as applied to federal statutes in "Gonzales v. O Centro Espirita" in 2006.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Of those Americans who have health insurance, most are covered by employer-sponsored health insurance. In 2010, Congress passed the Affordable Care Act (ACA), which relies on the Health Resources and Services Administration (HRSA), part of the Department of Health and Human Services (HHS), to specify what kinds of preventive care for women should be covered in certain employer-based health plans. HHS exempted religious employers (churches and their integrated auxiliaries, associations of churches, and any religious order), non-profit organizations that object to any required contraception, employers providing grandfathered plans (that have not had specific changes before March 23, 2010), and employers with fewer than 50 employees. The HRSA decided that all twenty contraceptives approved by the U.S. Food and Drug Administration (FDA) should be covered. Companies that refuse are fined $100 per individual per day, or they can replace their health coverage with higher wages and a calibrated tax.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Hobby Lobby is an arts and crafts company founded by billionaire David Green and owned by the Evangelical Christian Green family with about 21,000 employees. It provided health insurance covering the contraceptives Plan-B and Ella until it dropped its coverage in 2012, the year it filed its lawsuit. The Hobby Lobby case also involved Mardel Christian and Educational Supply, which is owned by Mart Green, one of David's sons.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Hobby Lobby's case was consolidated with another case by Conestoga Wood Specialties, a furniture company owned by the Mennonite Hahn family that has about 1,000 employees, represented by the Alliance Defending Freedom.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The plaintiffs believed that life began at conception which they equated to fertilization, and objected to their businesses providing health insurance coverage to their female employees of four FDA-approved contraceptives that the plaintiffs believed prevented implantation of a fertilized egg. The plaintiffs believed the following forms of birth control constituted an abortion:


title: Burwell v. Hobby Lobby Stores, Inc.

text: In September 2012, Hobby Lobby filed a lawsuit in the United States District Court for the Western District of Oklahoma against enforcement of the contraception rule based on the RFRA and the Free Exercise Clause of the First Amendment. On November 19, 2012, U.S. District Judge Joe L. Heaton denied Hobby Lobby's request for a preliminary injunction. On December 26, 2012, Justice Sonia Sotomayor issued an in-chambers opinion denying an injunction pending appeal. In March 2013, the United States Court of Appeals for the Tenth Circuit granted a hearing of the case. In June, the appeals court ruled that Hobby Lobby Stores, Inc. is a person who has religious freedom. Circuit Judge Timothy Tymkovich wrote for the five-judge en banc majority, over a three-judge dissent. Neil Gorsuch voted with the majority and also wrote an opinion on the case. The court ordered the government to stop enforcement of the contraception rule on Hobby Lobby and sent the case back to the district court, which granted preliminary injunction in July. In September, the government appealed to the U.S. Supreme Court.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Two other federal appeals courts ruled against the contraception coverage rule, while another two upheld it.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The case was previously titled "Sebelius v. Hobby Lobby". Sylvia Burwell was automatically substituted as petitioner when she was approved by the United States Senate as the Secretary of Health and Human Services after being nominated by President Barack Obama to replace Kathleen Sebelius following Sebelius' resignation on April 10, 2014.


title: Burwell v. Hobby Lobby Stores, Inc.

text: On November 26, the Supreme Court accepted and consolidated the case with "Conestoga Wood Specialties v. Sebelius." Two dozen amicus briefs support the government, and five dozen support the companies. American Freedom Law Center's brief argues that birth control harms women because men will only want them "for the satisfaction of [their] own desires." Another brief argues that the contraception rule leads to "the maximization of sexual activity". Two of the briefs oppose each other on the constitutionality of the RFRA. Two briefs that do not formally take sides oppose each other on whether the right to religion applies to corporations. One of those briefs argues that if shareholders are separated by the corporate veil from corporate liabilities, then their religious values are also separate from the corporation. It mentions the ruling in "Domino's Pizza, Inc. v. McDonald" made against the African American owner of JWM Investments whose contracts were breached due to racial discrimination. The brief argues that if JWM Investments could not suffer discrimination through its owner, then Hobby Lobby could not suffer religious burden through its owner. Two briefs were filed by LGBT groups concerned that future anti-discrimination laws would be pre-emptively harmed if employers could claim to be religiously exempt.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The three women in the court focused their questioning on Hobby Lobby's lawyer, Paul Clement, while the men focused on the administration's lawyer, Solicitor General Donald B. Verrilli Jr. Justice Sotomayor quoted the ruling from "United States v. Lee" (1982) saying that an employer can't deprive employees of a statutory right because of religious beliefs. Clement replied that "Lee" does not apply because it was a challenge against a tax rather than against a significant burden. Sotomayor said that instead of paying the burden of the penalty, Hobby Lobby could replace its health care with the equivalent expense of higher wages and a calibrated tax, which the government would use to pay for the employees' health care. Near the end of Clement's argument, Justice Kennedy expressed concern for the rights of the employees who may not agree with the religious beliefs of their employers. When Verrilli argued that the ruling in "Cutter v. Wilkinson" requires the court to weigh the impact on third parties in every RFRA case, Justice Scalia said that the RFRA does not require the court to balance the interest of the religious objector to the interest of other individuals. Verilli returned to "Lee," saying that granting an exemption to an employer should not impose the employer's religious faith on the employees.


title: Burwell v. Hobby Lobby Stores, Inc.

text: On June 30, 2014, Associate Justice Samuel Alito delivered the judgment of the court. Four justices (Roberts, Scalia, Kennedy, and Thomas) joined him to strike down the HHS mandate, as applied to closely held corporations with religious objections, and to prevent the plaintiffs from being compelled to provide contraception under their healthcare plans. The ruling was reached on statutory grounds, citing the RFRA, because the mandate was not the "least restrictive" method of implementing the government's interest. The ruling did not address Hobby Lobby's claims under the Free Exercise Clause of the First Amendment.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The court argued that the purpose of extending rights to corporations is to protect the rights of shareholders, officers, and employees. It said that "allowing Hobby Lobby, Conestoga, and Mardel to assert RFRA claims protects the religious liberty of the Greens and the Hahns." The court found that for-profit corporations could be considered "persons" under the RFRA. It noted that the HHS treats "nonprofit" corporations as "persons" within the meaning of RFRA. The court stated, "no conceivable definition of the term includes natural persons and nonprofit corporations, but not for-profit corporations." Responding to lower court judges' suggestion that the purpose of for-profit corporations "is simply to make money," the court said, "For-profit corporations, with ownership approval, support a wide variety of charitable causes, and it is not at all uncommon for such corporations to further humanitarian and other altruistic objectives." The court rejected the contention that "the Nation lacks a tradition of exempting for-profit corporations from generally applicable laws," pointing to a federal statute from 1993 that exempted any covered health care entity from engaging in "certain activities related to abortion".


title: Burwell v. Hobby Lobby Stores, Inc.

text: The court held that the HHS contraception mandate substantially burdens the exercise of religion, rejecting an argument that the $2,000-per-employee penalty for dropping insurance coverage is less than the average cost of health insurance. Responding to HHS's argument that the provision of coverage does not itself result in destruction of embryos, the Court asserted that the argument dodges the substantial burden question that the Court is supposed to address. The Court added, citing Jesuit moral manuals, that the argument is also the religious question of the morality of enabling the immoral acts of others, to which HHS had provided "a binding national answer". The Court argued that federal courts should not answer religious questions because they would in effect be deciding whether certain beliefs are flawed. The court argued that "companies would face a competitive disadvantage in retaining and attracting skilled workers," that increased wages for employees to buy individual coverage would be more costly than group health insurance, that any raise in wages would have to take income taxes into account, and that employers cannot deduct the penalty.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The court found it unnecessary to adjudicate on whether the HHS contraceptive mandate furthers a compelling government interest and held that HHS has not shown that the mandate is "the least restrictive means of furthering that compelling interest". The court argued that the most straightforward alternative would be "for the Government to assume the cost ..." and that HHS has not shown that it is not "a viable alternative". The court said that the RFRA can "require creation of entirely new programs". The court also pointed out that HHS already exempts any nonprofit organization from paying for any required contraception by allowing it to certify its religious objection to its insurance issuer, which must "[p]rovide separate payments for any contraceptive services required to be covered". However, the court said the approach might not necessarily be the least restrictive alternative for all religious claims.


title: Burwell v. Hobby Lobby Stores, Inc.

text: The court concluded by addressing "the possibility that discrimination in hiring, for example on the basis of race, might be cloaked as religious practice to escape legal sanction". The court said that their decision "provides no such shield", and that "prohibitions on racial discrimination are precisely tailored to achieve that critical goal." The court also said that the requirement to pay taxes despite any religious objection is different from the contraceptive mandate because "there simply is no less restrictive alternative to the categorical requirement to pay taxes." The court acknowledged the dissent's "worries about forcing the federal courts to apply RFRA to a host of claims made by litigants seeking a religious exemption from generally applicable laws ...", noting that this point was "made forcefully by the Court in "Smith."" The court responded by saying, "Congress, in enacting RFRA, took the position that 'the compelling interest test as set forth in prior Federal court rulings is a workable test for striking sensible balances between religious liberty and competing prior governmental interests' ... The wisdom of Congress's judgment on this matter is not our concern. Our responsibility is to enforce RFRA as written, and under the standard that RFRA prescribes, the HHS contraceptive mandate is unlawful."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Justice Anthony Kennedy wrote a concurring opinion, responding to the "respectful and powerful dissent", by emphasizing the limited nature of the ruling and saying that the government "makes the case that the mandate serves the Government's compelling interest in providing insurance coverage that is necessary to protect the health of female employees", but that the RFRA's least-restrictive way requirement is not met because "there is an existing, recognized, workable, and already-implemented framework to provide coverage," the one that HHS has devised for non-profit corporations with religious objections. "RFRA requires the Government to use this less restrictive means. As the Court explains, this existing model, designed precisely for this problem, might well suffice to distinguish the instant cases from many others in which it is more difficult and expensive to accommodate a governmental program to countless religious claims based on an alleged statutory right of free exercise." (Kennedy, J., concurring, pp. 3, 4)


title: Burwell v. Hobby Lobby Stores, Inc.

text: Justice Ruth Bader Ginsburg delivered the primary dissent, which was joined by Justice Sotomayor in full and by Justices Breyer and Kagan as to all but Part III–C–1 on "whether a corporation qualifies as a 'person' capable of exercising religion". Ginsburg began, "In a decision of startling breadth, the Court holds that commercial enterprises, including corporations, along with partnerships and sole proprietorships, can opt out of any law (saving only tax laws) they judge incompatible with their sincerely held religious beliefs. ... Compelling governmental interests in uniform compliance with the law, and disadvantages that religion-based opt-outs impose on others, hold no sway, the Court decides, at least when there is a 'less restrictive alternative.' And such an alternative, the Court suggests, there always will be whenever, in lieu of tolling an enterprise claiming a religion-based exemption, the government, i.e., the general public, can pick up the tab."


title: Burwell v. Hobby Lobby Stores, Inc.

text: She challenged the majority's unprecedented view of for-profit religion saying "Until this litigation, no decision of this Court recognized a for-profit corporation's qualification for a religious exemption from a generally applicable law, whether under the Free Exercise Clause or RFRA. The absence of such precedent is just what one would expect, for the exercise of religion is characteristic of natural persons, not artificial legal entities... Religious organizations exist to foster the interests of persons subscribing to the same religious faith. Not so of for-profit corporations. Workers who sustain the operations of those corporations commonly are not drawn from one religious community." Responding to the majority's argument that the government should "assume the cost" of contraceptives, Ginsburg said that "the nation's only dedicated source of federal funding for safety net family planning services ..." is not designed to absorb the unmet needs of those already insured. She noted that "a less restrictive alternative" has not been written into law by Congress. Ginsburg warns, "The Court, I fear, has ventured into a minefield ..."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Justices Breyer and Kagan wrote a one-paragraph dissenting opinion, saying that "the plaintiffs' challenge to the contraceptive coverage requirement fails on the merits" and that they "need not and do not decide whether either for-profit corporations or their owners may bring claims under the Religious Freedom Restoration Act of 1993."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Barbara Green, co-founder of Hobby Lobby, said "Today, the nation's highest court has reaffirmed the vital importance of religious liberty as one of our country's founding principles. The court's decision is a victory, not just for our family business, but for all who seek to live out their faith."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Conestoga CEO Anthony Hahn said, "Americans don't have to surrender their freedom when they open a family business."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Conservative and pro-life groups praised the ruling. "National Review" said that the Supreme Court ruling "[led] Alliance Defending Freedom attorney Matt Bowman to call "Hobby Lobby" an 'inclusive decision' that advances everyone's freedom." Susan B. Anthony List President Marjorie Dannenfelser said, "This is a great victory for religious liberty – the bedrock of our founding. In living out our religious convictions, there are certain things we must not do. This is why we are at a watershed moment. Religious people will no longer be ordered to take action that our religion says we must not take." Family Research Council President Tony Perkins said, "The Supreme Court has delivered one of the most significant victories for religious freedom in our generation. We are thankful the Supreme Court agreed that the government went too far by mandating that family businesses owners must violate their consciences under threat of crippling fines." The U.S. Conference of Catholic Bishops said, "We welcome the Supreme Court's decision to recognize that Americans can continue to follow their faith when they run a family business ... Now is the time to redouble our efforts to build a culture that fully respects religious freedom."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Pro-choice and civil-liberties groups criticized the ruling. Cecile Richards, president of the Planned Parenthood Action Fund, said, "Today, the Supreme Court ruled against American women and families, giving bosses the right to discriminate against women and deny their employees access to birth control coverage. This is a deeply disappointing and troubling ruling that will prevent some women, especially those working hourly-wage jobs and struggling to make ends meet, from getting birth control." Deputy legal director of the American Civil Liberties Union Louise Melling said, "This is a deeply troubling decision. For the first time, the highest court in the country has said that business owners can use their religious beliefs to deny their employees a benefit that they are guaranteed by law."


title: Burwell v. Hobby Lobby Stores, Inc.

text: In an editorial, the "New England Journal of Medicine" called the decision "a setback for both the ACA's foundational goal of access to universal health care and for women's health care specifically", voicing concern that "in assessing the competing claims about abortion and birth control, the Court's majority focused on the religious claims of the corporations without discussing scientific or medical opinions." In "JAMA Internal Medicine", Alta Charo wrote that "consistent with a disturbing trend among courts and legislatures to misstate or misuse scientific information in the context of women's reproductive rights and health, the Supreme Court's decision ignored the well-accepted distinction between contraception and abortion." The American Congress of Obstetricians and Gynecologists, representing 90% of U.S. board-certified gynecologists, supported a bill to overturn the "Hobby Lobby" ruling.


title: Burwell v. Hobby Lobby Stores, Inc.

text: White House spokesman Josh Earnest said, "Congress needs to take action to solve this problem that's been created and the administration stands ready to work with them to do so. President Obama believes that women should make personal health care decisions for themselves, rather than their bosses deciding for them. Today's decision jeopardizes the health of women that are employed by these companies."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Senate Majority Leader Harry Reid (D-Nev.) said, "If the Supreme Court will not protect women's access to health care, then Democrats will. We will continue to fight to preserve women's access to contraceptive coverage and keep bosses out of the examination room."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Senate Minority Leader Mitch McConnell said, "[T]he Obama administration cannot trample on the religious freedoms that Americans hold dear."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Senator Chuck Schumer (D-NY), who introduced the RFRA in 1993, said his law "was not intended to extend the same protection to for-profit corporations, whose very purpose is to profit from the open market."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Speaker of the House John Boehner (R-Ohio) said, "The mandate overturned today would have required for-profit companies to choose between violating their constitutionally-protected faith or paying crippling fines, which would have forced them to lay off employees or close their doors."


title: Burwell v. Hobby Lobby Stores, Inc.

text: House minority leader Nancy Pelosi (D-CA) said, "Although the Court restricted their ruling to 'closely held' companies, this ruling will immediately affect the lives of millions of women across the country. Over 90 percent of America's businesses are 'closely held', including such large employers as Koch Industries and Bechtel. Women should not be forced to jump through extra hoops to secure the fundamental health care they need. Allowing employers and CEOs to limit the health care available to employees is a gross violation of their workers' religious rights. It's just not her boss' business."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Senator Ted Cruz (R-Tex.) said, "Today's victory in the Hobby Lobby case is terrific news—but now is no time to rest. We cannot rely on the courts alone to defend our religious liberty."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Senator Orrin Hatch (R-Utah) said, "I applaud the Supreme Court's decision to protect the religious freedom of all Americans, both individually and collectively. The notion that religious freedom belongs only to some, and even then only in private, defies our nation's traditions, our laws, and our Constitution. And as the Supreme Court rightfully said today, the Religious Freedom Restoration Act could not have been clearer in saying religious liberty of all Americans must be equally protected and not unnecessarily burdened."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Rep. Michele Bachmann (R-Minn) said, "I am extremely encouraged by today's Supreme Court decision to uphold the religious liberty rights of the Green family of Hobby Lobby."


title: Burwell v. Hobby Lobby Stores, Inc.

text: "Forbes" reported that following the ruling in "Burwell v. Hobby Lobby", "the Supreme Court vacated the judgment against Eden Foods and sent the case back to the U.S. Court of Appeals for the Sixth Circuit for further consideration."


title: Burwell v. Hobby Lobby Stores, Inc.

text: On November 6, 2015 the Supreme Court of the United States decided it will hear arguments for the case of "Zubik v. Burwell" combined with six other challenges—including "Priests for Life v. Burwell", "Southern Nazarene University v. Burwell", "Geneva College v. Burwell",


title: Burwell v. Hobby Lobby Stores, Inc.

text: "Roman Catholic Archbishop of Washington v. Burwell", "East Texas Baptist University v. Burwell", "Little Sisters of the Poor Home for the Aged v. Burwell"—to the contraceptive mandate of Obamacare.


title: Burwell v. Hobby Lobby Stores, Inc.

text: On July 3, 2014, the Supreme Court granted a temporary exemption to the approach it suggested as a less restrictive alternative in "Hobby Lobby," where the plaintiffs would send a form (EBSA Form 700) to its insurance issuer, which would pay for the contraception. In an unsigned emergency injunction for Wheaton College in Illinois, the court said that instead of notifying its insurance issuer, Wheaton can notify the government. Once notified, the government should notify the issuer. Wheaton believed that by transferring the obligation to cover contraceptives to its insurance issuer, it was triggering that obligation. The emergency injunction does not constitute a ruling on the merits of Wheaton's religious objection. The court said "Nothing in this interim order affects the ability of the applicant's employees and students to obtain, without cost, the full range of FDA approved contraceptives."


title: Burwell v. Hobby Lobby Stores, Inc.

text: In a 15-page dissent joined by the other two women on the court, Justice Sonia Sotomayor criticized the majority's reasoning: "Wheaton's application comes nowhere near the high bar necessary to warrant an emergency injunction from this court ... The court's actions in this case create unnecessary costs and layers of bureaucracy, and they ignore a simple truth: The government must be allowed to handle the basic tasks of public administration in a manner that comports with common sense."


title: Burwell v. Hobby Lobby Stores, Inc.

text: The Supreme Court Justice Sotomayor granted a similar temporary injunction to the Little Sisters of the Poor at the end of 2013, just before the mandate was to go into effect.


title: Burwell v. Hobby Lobby Stores, Inc.

text: In dueling commentaries between regular SCOTUSblog contributor Marty Lederman and co-founder Tom Goldstein, Lederman argued that only Form 700 can require an insurance provider to pay for contraception coverage. Goldstein argued that an existing regulation allows the government to specify an alternative to Form 700. He pointed out that "the Court didn't accept Wheaton's most aggressive argument" that it cannot be required to do anything. He said that Justice Kennedy's concurrence is controlling and makes clear that the RFRA is not violated by requiring Wheaton to notify the government.


title: Burwell v. Hobby Lobby Stores, Inc.

text: A revised version of EBSA Form 700, effective August 2014, says "[a]s an alternative to using this form, an eligible organization may provide notice to the Secretary of Health and Human Services that the eligible organization has a religious objection to providing coverage for all or a subset of contraceptive services ...".


title: Burwell v. Hobby Lobby Stores, Inc.

text: In November 2022, "The New York Times" reported on a possible leak of the "Hobby Lobby" decision about two weeks prior to its formal announcement; this story was published following the leak and decision of "Dobbs v. Jackson Women's Health Organization" in June 2022 which overturned "Roe v. Wade" on abortion rights. Reverend Rob Schneck wrote to both Chief Justice John Roberts and to the "Times" stating that he had been told of which way "Hobby Lobby" was to be decided though a close associate after Schenck and his wife had a dinner party with Alito and his wife. At the time, Schneck used that information to inform Hobby Lobby and other religious organizations to prepare for the formal announcement of the decision. Schneck had opted to reveal this information in 2022 to aid in the investigation of the "Dobbs" decision leak. In 2011 through their connection to the Historical Society, Hobby Lobby's owners attended a Christmas party in Supreme Court chambers shortly before litigation was initiated which became Burwell v. Hobby Lobby Stores, Inc.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Although the court stated clearly that the decision is limited to the contraceptive mandate (Syllabus p. 4-5), the ruling is seen to have consequences extending far beyond contraception. Walter Dellinger, former acting solicitor general said, "for the first time, commercial enterprises could successfully claim religious exemptions from laws that govern everyone else." Fifteen states had filed a brief arguing that businesses would be able to deny coverage for transfusions, stem cell treatments, and psychiatric care. In line with the dissenting opinion, "The American Prospect" asked, "[W]ill the taxpayers have to send a check to employees if employers feel that minimum wage laws violate their religious beliefs?" Jonathan Rauch, a senior fellow at the Brookings Institution, said that objections to paying health benefits for same-sex spouses will get traction. The National Gay and Lesbian Task Force (NGLT) and the National Center for Lesbian Rights withdrew their support for the Employment Non-Discrimination Act (ENDA) passed by the Senate, saying that its religious exemptions would allow companies to fire or refuse to hire LGBT workers in light of the "Hobby Lobby" ruling. NGLT executive director Rea Carey said, "We do not take this move lightly. We've been pushing for this bill for 20 years."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Such concerns are focused on the court's application of the federal RFRA law and were driven by national controversy over a state RFRA amendment bill in Arizona. Douglas Laycock, law professor at the University of Virginia, said, "The whole secular left has decided" that RFRA laws "are very dangerous because they care so much more about the contraception cases and gay rights." He said RFRA laws are mischaracterized because they do not dictate outcomes favoring religious objectors, they only require courts to use the highest standard of scrutiny on any law challenged. Mark Kernes, Senior Editor and Chief Legal Analyst for AVN magazine stated in an op-ed piece, "If the Hobby Lobby decision supports the 'right' of companies not to make available birth control that will prevent women from 'catching' a pregnancy, what's to keep those same religious companies from arguing that providing access to PrEP drugs like Truvada, which help prevent gays (and, admittedly, everyone) from catching HIV shouldn't similarly be excluded from their health plans?"


title: Burwell v. Hobby Lobby Stores, Inc.

text: In 2021, Senator Cory Booker introduced a bill called the Do No Harm Act to reverse Burwell v. Hobby Lobby.


title: Burwell v. Hobby Lobby Stores, Inc.

text: As of April 2022, there is an expectation that "Hobby Lobby 2.0" is forthcoming should President Biden pass changes to Obamacare regarding extensions for protections for trans people and the interpretation of discrimination on the basis of sex.


title: Burwell v. Hobby Lobby Stores, Inc.

text: Ian Millhiser from Vox.com argued that as a general rule in religious liberty cases prior to the Hobby Lobby decision religion can't be used to diminish the rights of others. He pointed to the 1982 U.S. Supreme Court case "United States v. Lee (1982)" (1982) in which the Court declared “when followers of a particular sect enter into commercial activity as a matter of choice, the limits they accept on their own conduct as a matter of conscience and faith are not to be superimposed on the statutory schemes which are binding on others in that activity.” According to Millhiser the Hobby Lobby decision marks the first time "rights of religious believers could trump the rights of others." Marcia Greenberger, co-president of the National Women's Law Center, argued in the same direction Millhiser by saying that the Supreme Court has never ruled that companies have religious beliefs and that "it has never held that religious exercise provides a license to harm others, or violate the rights of third parties."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Louise Melling, ACLU deputy legal director, said religious freedom "gives us all the right to hold our beliefs, but it doesn't give you the right to impose your beliefs on others, to discriminate against others." The editorial board of "The New York Times" wrote that the decision "swept aside accepted principles of corporate law and religious liberty to grant owners of closely held, for-profit companies an unprecedented right to impose their religious views on employees." A Fox News columnist wrote, "..., with all of the debate about the religious beliefs of the Hobby Lobby owners, what about the religious beliefs of their employees? They are just as important, and should not be trampled upon." The director of the United Church of Christ's Washington, D.C. office, said that the ruling "may embolden private employers to claim religious objections to particular health care services, in effect forcing their own religious views upon their employees." Former Secretary of State Hillary Clinton said, "It's the first time that our court has said that a closely held corporation has the rights of a person when it comes to religious freedom, which means that the ... corporation's employers can impose their religious beliefs on their employees." The Center for American Progress said that the ruling "moves in the direction this court has been moving already, which is talking about corporate personhood—really treating corporations like people, saying that the corporation has a religion itself and that should be imposed on its employees." Interfaith Alliance leader Rev. Welton Gaddy said, "The First Amendment is at its best when it is used to protect the rights of minorities from the whims of the powerful. Today's decision, which gives the powerful the right to force their religious beliefs on those around them, is a far cry from the best traditions of religious freedom."


title: Burwell v. Hobby Lobby Stores, Inc.

text: Scholars on the other side (including some on the left) disagree, arguing that companies owned and run by liberals will likewise benefit from the freedom to operate according to their conscience or values—which has not been viewed as "imposing" views, because people routinely choose whom to associate with based on philosophical compatibility.


title: Burwell v. Hobby Lobby Stores, Inc.

text: "The New York Times" editor Dorothy J. Samuels invoked the cautionary adage "be careful what you wish for", speculating that "if owners indicate that they are not entirely separate from their corporation—by denying corporation employees' birth control coverage based on their personal religious beliefs—the case could be made in future state-court litigation that they have waived their right to be shielded from responsibility for corporate financial liabilities." The dean of the UC Irvine School of Law, Erwin Chemerinsky, said, "The liabilities of the corporation are not attributed to the owners, so why should the owners be able to attribute their beliefs to the company?" Several legal scholars wrote an amicus brief to the Supreme Court for this case arguing this danger, while scholars on the other side counter that incorporated non-profit organizations enjoy liability protection despite their activities based on religious or other values/conscience-based causes.


title: Wisdom of the crowd

text: The wisdom of the crowd is the collective opinion of a diverse independent group of individuals rather than that of a single expert. This process, while not new to the Information Age, has been pushed into the mainstream spotlight by social information sites such as Quora, Reddit, Stack Exchange, Wikipedia, Yahoo! Answers, and other web resources which rely on collective human knowledge. An explanation for this phenomenon is that there is idiosyncratic noise associated with each individual judgment, and taking the average over a large number of responses will go some way toward canceling the effect of this noise.


title: Wisdom of the crowd

text: Trial by jury can be understood as at least partly relying on wisdom of the crowd, compared to bench trial which relies on one or a few experts. In politics, sometimes sortition is held as an example of what wisdom of the crowd would look like. Decision-making would happen by a diverse group instead of by a fairly homogenous political group or party. Research within cognitive science has sought to model the relationship between wisdom of the crowd effects and individual cognition.


title: Wisdom of the crowd

text: A large group's aggregated answers to questions involving quantity estimation, general world knowledge, and spatial reasoning has generally been found to be as good as, but often superior to, the answer given by any of the individuals within the group.


title: Wisdom of the crowd

text: Jury theorems from social choice theory provide formal arguments for wisdom of the crowd given a variety of more or less plausible assumptions. Both the assumptions and the conclusions remain controversial, even though the theorems themselves are not. The oldest and simplest is Condorcet's jury theorem (1785).


title: Wisdom of the crowd

text: Aristotle is credited as the first person to write about the "wisdom of the crowd" in his work "Politics". According to Aristotle, "it is possible that the many, though not individually good men, yet when they come together may be better, not individually but collectively, than those who are so, just as public dinners to which many contribute are better than those supplied at one man's cost".


title: Wisdom of the crowd

text: The classic wisdom-of-the-crowds finding involves point estimation of a continuous quantity. At a 1906 country fair in Plymouth, 800 people participated in a contest to estimate the weight of a slaughtered and dressed ox. Statistician Francis Galton observed that the median guess, 1207 pounds, was accurate within 1% of the true weight of 1198 pounds. This has contributed to the insight in cognitive science that a crowd's individual judgments can be modeled as a probability distribution of responses with the median centered near the true value of the quantity to be estimated.


title: Wisdom of the crowd

text: In recent years, the "wisdom of the crowd" phenomenon has been leveraged in business strategy and advertising spaces. Firms such as Napkin Labs aggregate consumer feedback and brand impressions for clients. Meanwhile, companies such as Trada invoke crowds to design advertisements based on clients' requirements.


title: Wisdom of the crowd

text: Non-human examples are prevalent. For example, the golden shiner is a fish that prefers shady areas. The single shiner has a very difficult time finding shady regions in a body of water whereas a large group is much more efficient at finding the shade.


title: Wisdom of the crowd

text: Although classic wisdom-of-the-crowds findings center on point estimates of single continuous quantities, the phenomenon also scales up to higher-dimensional problems that do not lend themselves to aggregation methods such as taking the mean. More complex models have been developed for these purposes. A few examples of higher-dimensional problems that exhibit wisdom-of-the-crowds effects include:


title: Wisdom of the crowd

text: In further exploring the ways to improve the results, a new technique called the "surprisingly popular" was developed by scientists at MIT's Sloan Neuroeconomics Lab in collaboration with Princeton University. For a given question, people are asked to give two responses: What they think the right answer is, and what they think popular opinion will be. The averaged difference between the two indicates the correct answer. It was found that the "surprisingly popular" algorithm reduces errors by 21.3 percent in comparison to simple majority votes, and by 24.2 percent in comparison to basic confidence-weighted votes where people express how confident they are of their answers and 22.2 percent compared to advanced confidence-weighted votes, where one only uses the answers with the highest average.


title: Wisdom of the crowd

text: In the context of wisdom of the crowd, the term "crowd" takes on a broad meaning. One definition characterizes a crowd as a group of people amassed by an open call for participation. While crowds are often leveraged in online applications, they can also be utilized in offline contexts. In some cases, members of a crowd may be offered monetary incentives for participation. Certain applications of "wisdom of the crowd", such as jury duty in the United States, mandate crowd participation.


title: Wisdom of the crowd

text: The insight that crowd responses to an estimation task can be modeled as a sample from a probability distribution invites comparisons with individual cognition. In particular, it is possible that individual cognition is probabilistic in the sense that individual estimates are drawn from an "internal probability distribution." If this is the case, then two or more estimates of the same quantity from the same person should average to a value closer to ground truth than either of the individual judgments, since the effect of statistical noise within each of these judgments is reduced. This of course rests on the assumption that the noise associated with each judgment is (at least somewhat) statistically independent. Thus, the crowd needs to be independent but also diversified, in order to allow a variety of answers. The answers on the ends of the spectrum will cancel each other, allowing the wisdom of the crowd phenomena to take its place. Another caveat is that individual probability judgments are often biased toward extreme values (e.g., 0 or 1). Thus any beneficial effect of multiple judgments from the same person is likely to be limited to samples from an unbiased distribution.


title: Wisdom of the crowd

text: Vul and Pashler (2008) asked participants for point estimates of continuous quantities associated with general world knowledge, such as "What percentage of the world's airports are in the United States?" Without being alerted to the procedure in advance, half of the participants were immediately asked to make a second, different guess in response to the same question, and the other half were asked to do this three weeks later. The average of a participant's two guesses was more accurate than either individual guess. Furthermore, the averages of guesses made in the three-week delay condition were more accurate than guesses made in immediate succession. One explanation of this effect is that guesses in the immediate condition were less independent of each other (an anchoring effect) and were thus subject to (some of) the same kind of noise. In general, these results suggest that individual cognition may indeed be subject to an internal probability distribution characterized by stochastic noise, rather than consistently producing the best answer based on all the knowledge a person has. These results were mostly confirmed in a high-powered pre-registered replication. The only result that was not fully replicated was that a delay in the second guess generates a better estimate.


title: Wisdom of the crowd

text: Hourihan and Benjamin (2010) tested the hypothesis that the estimate improvements observed by Vul and Pashler in the delayed responding condition were the result of increased independence of the estimates. To do this Hourihan and Benjamin capitalized on variations in memory span among their participants. In support they found that averaging repeated estimates of those with lower memory spans showed greater estimate improvements than the averaging the repeated estimates of those with larger memory spans.


title: Wisdom of the crowd

text: Rauhut and Lorenz (2011) expanded on this research by again asking participants to make estimates of continuous quantities related to real world knowledge – however, in this case participants were informed that they would make five consecutive estimates. This approach allowed the researchers to determine, firstly, the number of times one needs to ask oneself in order to match the accuracy of asking others and then, the rate at which estimates made by oneself improve estimates compared to asking others. The authors concluded that asking oneself an infinite number of times does not surpass the accuracy of asking just one other individual. Overall, they found little support for a so-called "mental distribution" from which individuals draw their estimates; in fact, they found that in some cases asking oneself multiple times actually reduces accuracy. Ultimately, they argue that the results of Vul and Pashler (2008) overestimate the wisdom of the "crowd within" – as their results show that asking oneself more than three times actually reduces accuracy to levels below that reported by Vul and Pashler (who only asked participants to make two estimates).


title: Wisdom of the crowd

text: Müller-Trede (2011) attempted to investigate the types of questions in which utilizing the "crowd within" is most effective. He found that while accuracy gains were smaller than would be expected from averaging ones' estimates with another individual, repeated judgments lead to increases in accuracy for both year estimation questions (e.g., when was the thermometer invented?) and questions about estimated percentages (e.g., what percentage of internet users connect from China?). General numerical questions (e.g., what is the speed of sound, in kilometers per hour?), however, did not show improvement with repeated judgments, while averaging individual judgments with those of a random other did improve accuracy. This, Müller-Trede argues, is the result of the bounds implied by year and percentage questions.


title: Wisdom of the crowd

text: Van Dolder and Van den Assem (2018) studied the "crowd within" using a large database from three estimation competitions organised by Holland Casino. For each of these competitions, they find that within-person aggregation indeed improves accuracy of estimates. Furthermore, they also confirm that this method works better if there is a time delay between subsequent judgments. However, even when there is considerable delay between estimates, the benefit pales against that of between-person aggregation: the average of a large number of judgements from the same person is barely better than the average of two judgements from different people.


title: Wisdom of the crowd

text: Herzog and Hertwig (2009) attempted to improve on the "wisdom of many in one mind" (i.e., the "crowd within") by asking participants to use dialectical bootstrapping. Dialectical bootstrapping involves the use of dialectic (reasoned discussion that takes place between two or more parties with opposing views, in an attempt to determine the best answer) and bootstrapping (advancing oneself without the assistance of external forces). They posited that people should be able to make greater improvements on their original estimates by basing the second estimate on antithetical information. Therefore, these second estimates, based on different assumptions and knowledge than that used to generate the first estimate would also have a different error (both systematic and random) than the first estimate – increasing the accuracy of the average judgment. From an analytical perspective dialectical bootstrapping should increase accuracy so long as the dialectical estimate is not too far off and the errors of the first and dialectical estimates are different. To test this, Herzog and Hertwig asked participants to make a series of date estimations regarding historical events (e.g., when electricity was discovered), without knowledge that they would be asked to provide a second estimate. Next, half of the participants were simply asked to make a second estimate. The other half were asked to use a consider-the-opposite strategy to make dialectical estimates (using their initial estimates as a reference point). Specifically, participants were asked to imagine that their initial estimate was off, consider what information may have been wrong, what this alternative information would suggest, if that would have made their estimate an overestimate or an underestimate, and finally, based on this perspective what their new estimate would be. Results of this study revealed that while dialectical bootstrapping did not outperform the wisdom of the crowd (averaging each participants' first estimate with that of a random other participant), it did render better estimates than simply asking individuals to make two estimates.


title: Wisdom of the crowd

text: Hirt and Markman (1995) found that participants need not be limited to a consider-the-opposite strategy in order to improve judgments. Researchers asked participants to consider-an-alternative – operationalized as any plausible alternative (rather than simply focusing on the "opposite" alternative) – finding that simply considering an alternative improved judgments.


title: Wisdom of the crowd

text: Not all studies have shown support for the "crowd within" improving judgments. Ariely and colleagues asked participants to provide responses based on their answers to true-false items and their confidence in those answers. They found that while averaging judgment estimates between individuals significantly improved estimates, averaging repeated judgment estimates made by the same individuals did not significantly improve estimates.


title: Wisdom of the crowd

text: Wisdom-of-the-crowds research routinely attributes the superiority of crowd averages over individual judgments to the elimination of individual noise, an explanation that assumes independence of the individual judgments from each other. Thus the crowd tends to make its best decisions if it is made up of diverse opinions and ideologies.


title: Wisdom of the crowd

text: Averaging can eliminate random errors that affect each person's answer in a different way, but not systematic errors that affect the opinions of the entire crowd in the same way. So for instance, a wisdom-of-the-crowd technique would not be expected to compensate for cognitive biases.


title: Wisdom of the crowd

text: Scott E. Page introduced the diversity prediction theorem: "The squared error of the collective prediction equals the average squared error minus the predictive diversity". Therefore, when the diversity in a group is large, the error of the crowd is small.


title: Wisdom of the crowd

text: Miller and Stevyers reduced the independence of individual responses in a wisdom-of-the-crowds experiment by allowing limited communication between participants. Participants were asked to answer ordering questions for general knowledge questions such as the order of U.S. presidents. For half of the questions, each participant started with the ordering submitted by another participant (and alerted to this fact), and for the other half, they started with a random ordering, and in both cases were asked to rearrange them (if necessary) to the correct order. Answers where participants started with another participant's ranking were on average more accurate than those from the random starting condition. Miller and Steyvers conclude that different item-level knowledge among participants is responsible for this phenomenon, and that participants integrated and augmented previous participants' knowledge with their own knowledge.


title: Wisdom of the crowd

text: Crowds tend to work best when there is a correct answer to the question being posed, such as a question about geography or mathematics. When there is not a precise answer crowds can come to arbitrary conclusions.


title: Wisdom of the crowd

text: The wisdom of the crowd effect is easily undermined. Social influence can cause the average of the crowd answers to be wildly inaccurate, while the geometric mean and the median are far more robust.


title: Wisdom of the crowd

text: Experiments run by the Swiss Federal Institute of Technology found that when a group of people were asked to answer a question together they would attempt to come to a consensus which would frequently cause the accuracy of the answer to decrease. E.g. what is the length of a border between two countries? One suggestion to counter this effect is to ensure that the group contains a population with diverse backgrounds.


title: Wisdom of the crowd

text: Research from the Good Judgment Project showed that teams organized in prediction polls can avoid premature consensus and produce aggregate probability estimates that are more accurate than those produced in prediction markets.


title: Standard electrode potential

text: In electrochemistry, standard electrode potential formula_1, or formula_2, is a measure of the reducing power of any element or compound. The IUPAC "Gold Book" defines it as: ""the value of the standard emf (electromotive force) of a cell in which molecular hydrogen under standard pressure is oxidized to solvated protons at the left-hand electrode"".


title: Standard electrode potential

text: The basis for an electrochemical cell, such as the galvanic cell, is always a redox reaction which can be broken down into two half-reactions: oxidation at anode (loss of electron) and reduction at cathode (gain of electron). Electricity is produced due to the difference of electric potential between the individual potentials of the two metal electrodes with respect to the electrolyte.


title: Standard electrode potential

text: Although the overall potential of a cell can be measured, there is no simple way to accurately measure the electrode/electrolyte potentials in isolation. The electric potential also varies with temperature, concentration and pressure. Since the oxidation potential of a half-reaction is the negative of the reduction potential in a redox reaction, it is sufficient to calculate either one of the potentials. Therefore, standard electrode potential is commonly written as standard reduction potential. At each electrode-electrolyte interface there is a tendency of metal ions from the solution to deposit on the metal electrode trying to make it positively charged. At the same time, metal atoms of the electrode have a tendency to go into the solution as ions and leave behind the electrons at the electrode trying to make it negatively charged. At


title: Standard electrode potential

text: equilibrium, there is a separation of charges and depending on the tendencies of the two opposing reactions, the electrode may be positively or negatively charged with respect to the solution. A potential difference develops between the electrode and the electrolyte which is called the electrode potential. When the concentrations of all the species involved in a half-cell is unity then the electrode potential is known as standard electrode potential. According to IUPAC convention, standard reduction potentials are now called standard electrode potentials. In a galvanic cell, the half-cell in which oxidation takes place is called anode and it has a negative potential with respect to the solution. The other half-cell in which reduction takes place is called cathode and it has a positive potential with respect to the solution. Thus, there exists a potential difference between the two electrodes and as soon as the switch is in the on position the electrons flow from negative electrode to positive electrode. The direction of current flow is opposite to that of electron flow.


title: Standard electrode potential

text: The electrode potential cannot be obtained empirically. The galvanic cell potential results from a "pair" of electrodes. Thus, only one empirical value is available in a pair of electrodes and it is not possible to determine the value for each electrode in the pair using the empirically obtained galvanic cell potential. A reference electrode, standard hydrogen electrode (SHE), for which the potential is "defined" or agreed upon by convention, needed to be established. In this case the standard hydrogen electrode is set to 0.00 V and any electrode, for which the electrode potential is not yet known, can be paired with standard hydrogen electrode—to form a galvanic cell—and the galvanic cell potential gives the unknown electrode's potential. Using this process, any electrode with an unknown potential can be paired with either the standard hydrogen electrode or another electrode for which the potential has already been derived and that unknown value can be established.


title: Standard electrode potential

text: Since the electrode potentials are conventionally defined as reduction potentials, the sign of the potential for the metal electrode being oxidized must be reversed when calculating the overall cell potential. The electrode potentials are independent of the number of electrons transferred —they are expressed in volts, which measure energy per electron transferred—and so the two electrode potentials can be simply combined to give the overall "cell" potential even if different numbers of electrons are involved in the two electrode reactions.


title: Standard electrode potential

text: For practical measurements, the electrode in question is connected to the positive terminal of the electrometer, while the standard hydrogen electrode is connected to the negative terminal.


title: Standard electrode potential

text: A reversible electrode is an electrode that owes its potential to changes of a reversible nature. A first condition to be fulfilled is that the system is close to the chemical equilibrium. A second set of conditions is that the system is submitted to very small solicitations spread on a sufficient period of time so, that the chemical equilibrium conditions nearly always prevail. In theory, it is very difficult to experimentally achieve reversible conditions because any perturbation imposed to a system near equilibrium in a finite time forces it out of equilibrium. However, if the solicitations exerted on the system are sufficiently small and applied slowly, one can consider an electrode to be reversible. By nature, electrode reversibility depends on the experimental conditions and the way the electrode is operated. For example, electrodes used in electroplating are operated with a high over-potential to force the reduction of a given metal cation to be deposited onto a metallic surface to be protected. Such a system is far from equilibrium and continuously submitted to important and constant changes in a short period of time. Electrodes used in electroplating do not represent a reversible system and are also consumed during their use.


title: Standard electrode potential

text: The larger the value of the standard reduction potential, the easier it is for the element to be reduced (gain electrons); in other words, they are better oxidizing agents.


title: Standard electrode potential

text: The highly positive standard reduction potential of F means it is reduced easily and is therefore a good oxidizing agent. In contrast, the greatly negative standard reduction potential of Li indicates that it is not easily reduced. Instead, Li would rather undergo oxidation (hence it is a good reducing agent).


title: Standard electrode potential

text: Zn has a standard reduction potential of −0.76 V and thus can be oxidized by any other electrode whose standard reduction potential is greater than −0.76 V (e.g., H (0 V), Cu (0.34 V), F (2.87 V)) and can be reduced by any electrode with standard reduction potential less than −0.76 V (e.g. H (−2.23 V), Na (−2.71 V), Li (−3.05 V)).


title: Standard electrode potential

text: In a galvanic cell, where a spontaneous redox reaction drives the cell to produce an electric potential, Gibbs free energy formula_3 must be negative, in accordance with the following equation:


title: Standard electrode potential

text: where formula_12 is the standard potential at the cathode (called as standard cathodic potential or standard reduction potential and formula_13 is the standard potential at the anode (called as standard anodic potential or standard oxidation potential) as given in the table of standard electrode potential.


title: Mess

text: The mess (also called a mess deck aboard ships) is a designated area where military personnel socialize, eat and (in some cases) live. The term is also used to indicate the groups of military personnel who belong to separate messes, such as the officers' mess, the chief petty officer mess, and the enlisted mess. In some civilian societies this military usage has been extended to the eating arrangements of other disciplined services such as fire fighting and police forces.


title: Mess

text: The root of "mess" is the Old French "mes", "portion of food" (cf. modern French "mets"), drawn from the Latin verb "mittere", meaning "to send" and "to put" (cf. modern French "mettre"), the original sense being "a course of a meal put on the table"; cfr. also the modern Italian "portata" with the same meaning, past participle of "portare", "to bring". This sense of "mess", which appeared in English in the 13th century, was often used for cooked or liquid dishes in particular, as in the "mess of pottage" (porridge or soup) or Eton mess.


title: Mess

text: Messing in the Canadian Forces generally follows the British model (see United Kingdom below), from which most traditions have descended. Basic regulations regarding the establishment and administration of messes is contained in the King's Regulations and Orders and the Canadian Forces Administrative Orders.


title: Mess

text: As in the British Forces, there are normally three messes: the officers' mess (called the wardroom in naval establishments), for commissioned officers and officer cadets; the warrant Officers' and sergeants' mess (Navy: chiefs' and petty officers' mess), for senior non-commissioned officers and warrant officers; and the junior ranks mess, for junior non-commissioned officers, privates, and seamen. Some bases, such as CFB Kingston in the 1980s, had a master corporals' mess separate from the junior ranks'; all of these, with the exception of the CFB Valcartier master corporals mess (known as the "Mess des chefs"), have since been amalgamated with the junior ranks' messes. Certain other bases, mainly training establishments such as HMCS "Venture" have messes known as the gun room for the use of subordinate officers (naval or officer cadets).


title: Mess

text: Most bases and stations have three messes (officers', warrant officers' and sergeants', and junior ranks'). Many of these establishments have lodger units (such as air squadrons, army regiments, etc.) who also have their own messes. All of His Majesty's Canadian ships have three messes aboard; this extends to Naval Reserve divisions and other naval shore establishments which bear the title HMCS (see stone frigate). Due to limited budgets and declining revenues, many messes have been forced to close or amalgamate: for example, at CFS St. John's, the junior ranks' mess of the Newfoundland Militia District closed, its members moving to the station's junior ranks'; the station's officers' mess and warrant officers' and sergeants' mess later amalgamated.


title: Mess

text: All Canadian Forces personnel, regular and reserve, must belong to a mess, and are termed "ordinary members" of their particular mess. Although normally on federal property, messes have been ordered to comply with the legal drinking age laws of their province; for example, an 18-year-old soldier may legally consume alcohol in a Quebec mess, but not in one in Ontario, where the legal age is 19 years. However, despite being underage, the soldier may not be prohibited "entry" into the mess.


title: Mess

text: Canadian Forces personnel are normally welcome in any mess of their appropriate rank group, regardless of element; thus a regimental sergeant-major of an infantry battalion is welcome in a chiefs' and petty officers' mess (inter-service rivalries notwithstanding). Personnel of a different rank (except as noted below) must ask for permission to enter; that may be granted by the president of the mess committee, his designate, or the senior member present.


title: Mess

text: These restrictions are normally waived on certain special occasions, when the messes are "opened" to all personnel, regardless of rank. These occasions may include (and will be locally published by the mess committee)::


title: Mess

text: The commanding officer of the establishment or unit that owns the mess is permitted access to all his messes; thus a ship's captain has access to the vessel's chiefs' and petty officers' mess, the commanding officer of a regiment may enter any of the regimental messes, and the base commander of a Canadian Forces base is welcome in any of the base's messes. In practice, commanding officers rarely enter anything other than the officers' mess unless invited, as a point of etiquette. In addition, duty personnel — such as a duty NCO or officer of the watch — or the military police have access to any and all messes for the purposes of maintaining good order and discipline. Chaplains are usually welcomed in all messes.


title: Mess

text: As in the UK, Canadian messes are run by the mess committee, a group democratically elected by the members of the mess. One exception is on warships, where the president of the junior ranks mess is appointed by the commanding officer. The committee members are generally the same as those of their British counterparts, with the addition of special representatives for such things as sports, housing, morale, etc. These positions are normally spelled out in the mess constitution, which sets out the bylaws, regulations, and guidelines for such things as conduct of mess meetings, associate memberships, dress regulations within the mess, or booking of the mess by civilian organizations. The constitution and any amendments are voted upon by the members of the mess.


title: Mess

text: 1. HBG ("Heimbetriebsgesellschaft") - More commonly called Enlisted Mess ("Mannschaftsheim"): it is common for most bases to have one, where food and drink can be purchased. Newspapers and in some cases equipment and souvenirs such as key chains may also be available. There is generally no strict regulation of conduct, even though access is not limited to enlisted personnel, and NCOs or officers may also be present, ensuring some regulation of conduct.


title: Mess

text: 2. UHG ("Unteroffizierheim" or "Unteroffizierheimgesellschaft") ("Gesellschaft" lit. society) - also called UK (NCO Comradeship/"Unteroffizierkameradschaft") - Non-commissioned Officers' Mess: this is the area where NCOs can dine or spend their evenings. As opposed to the HBG, the UHG has a constitution, bylaws and a board. Access is usually restricted to NCOs, while officers can gain entry, even though it is usually frowned upon by the NCOs. Some bases have a joint NCOs' and Officers' Mess.


title: Mess

text: 3. OHG (Officers' Mess/"Offizierheimgesellschaft") - Also called Casino ("Kasino" or "Offizierkasino"). Much like the UHG, the "Kasino" also has a constitution, bylaws and a board. Gentlemanly conduct is mandatory: for instance upon entering the main hall, officers are expected to stand at attention and perform a small bow. Additionally, veterans' meetings are usually held either in a UHG or in a Kasino. As with the UHG, Kasinos have permanent personnel, as a general rule enlisted men, called "Ordonnanzen", a military term for waiter or barman. Some Kasinos have grand pianos, and hold recitals, as well as having music played during luncheons or dinners. Official events such as balls and unofficial events such as weddings, informational events and the like, are held here.


title: Mess

text: The German Navy call their messes "Messen", with the distinction "Offiziermesse". The land-based messes are also called "Offiziermessen".


title: Mess

text: The Indian Army follows a system similar to the British. A typical regiment/unit would have one mess and two clubs, one for the commissioned officers, club for the Junior Commissioned Officers (JCO) and one for the NCOs. Havildars/Daffadars (equivalent to Sergeants) are considered to be NCOs. The Air Force, however has an SNCO (Sr. NCO) mess for Warrant Officers and sergeants, while lower-ranking NCOs would be members of the NCO's mess.


title: Mess

text: In the officer's mess and the JCO's club, there also is rank of Mess Havildar. A Mess Havildar is a senior NCO who manages and executes the day-to-day activities of the mess/club.


title: Mess

text: On Republic Day (Jan 26) the JCOs are formally invited for cocktails at the Officers mess. This is reciprocated on Independence Day (Aug 15) by the JCOs at the JCOs Club.


title: Mess

text: In the Israeli Navy, although Hebrew speaking, dining rooms on the Missile Ships, Dolphin submarines, and the kitchen in the Patrol Boats are named Messes, Crew Mess and Officers' Mess. Also, every special meal brought by a crewmember, say celebrating a birthday or a rank promotion, is called Mess.


title: Mess

text: Officers and SNCOs are required under King's Regulations to be a member of a mess and unmarried members usually live, eat, and socialise in them. The JNCOs mess if established is normally used for socialising only, JNCOs usually being accommodated in barrack blocks eating in the cookhouse alongside private soldiers and able rates. Depending on circumstance, such as lack of finance or space, some regiments may have a JNCO "club" instead of a proper mess. Members of their mess are also required to pay a subscription fee for supplies and upkeep. The amount is decided upon by the commanding officer within the limits stipulated by the Regulations.


title: Mess

text: Soldiers, sailors or air personnel are welcome in any mess for their rank or equivalent, should they be away from their home unit, as long as they are paying dues in at least one mess. For the Warrant Officers' and Sergeants' Mess the highest ranking (normally the regimental sergeant major) member is known as the Presiding Member.


title: Mess

text: A mess is run by the Mess Committee, a group democratically elected by the members of the mess (except wardrooms), but normally agreed by the commanding officer or regimental sergeant major.


title: Mess

text: Some messes also have a Senior Living-In Member (SLIM) who represents the living-in members and supervises their conduct.


title: Mess

text: The commanding officer of the unit has right of veto over the mess, and any changes or events must have his approval. The CO is allowed into any mess (because they are legally all his), but it is often considered an abuse of power, unbecoming conduct or disturbing the order for a CO to drink in a lower rank mess, except when invited on special occasions.


title: Mess

text: The Officers' Mess in a Royal Navy ship or base is called the wardroom. Associated with the wardroom is a gunroom, the mess for midshipmen and occasionally junior sub-lieutenants. The captain of a vessel is not normally a member of the wardroom, which is always run by the first lieutenant or executive officer (XO), thereby known as the Mess President ("Mess Prez"). This post is part of the job of being a ship's XO. Other committee members are generally appointed (voluntarily or otherwise) by the XO.


title: Mess

text: Mess dress is the military term for the formal evening dress worn in the mess or at other formal occasions. It is also known as mess kit. Mess dress would be worn at occasions requiring white tie or black tie.


title: Mess

text: In the United States Army, officers historically have had to purchase their own food using funds allocated to each officer. In the far-flung forts of the American Old West, officers would organize their food service in two ways:


title: Mess

text: The mess now is called a "dining facility" or "Dining Facilities Administration Center" (DFAC). The Officers' Club ("O Club") is an outgrowth comparable to the Officers' Open Mess, but also providing areas to allow officers to entertain guests. A similar version for enlisted personnel is the "E Club". "Mess" also describes the formal affair of having a "dining in", held for military members and closed to the public, or a "dining out", a social event for military personnel and their families.


title: Mess

text: For much of the 20th century the Army's mess food selection was spartan, but after the end of the draft they changed to a food court model with more variety including fast food, while also making fast food franchises available on bases. In 2011, the Army rolled out a program known as "Soldier Athlete" which promotes healthier foods including low-fat milk, whole grains, and veggie wraps.


title: Mess

text: At most United States Navy shore installations, galleys (previously called Enlisted Dining Facilities in the 1970s and early 1980s) provide messing for sailors (and, if assigned, enlisted marines) ashore and as an option for sailors (and, if assigned, enlisted marines) aboard ships while in port at those installations. Commissioned officers may use these facilities if in a "duty officer" status (e.g., squadron duty officer, command duty officer, etc.) under the pretext of "inspecting/sampling" the mess.


title: Mess

text: In addition to galleys ashore, various social clubs with dining facilities may also exist. These are enlisted clubs for sailors in the grade of Petty Officer First Class (E-6) and below; chief petty officer clubs for CPOs (E-7), senior chief petty officers (E-8) and MCPOs (E-9); and officers' clubs for commissioned officers, although many have been closed, merged into combination rnlisted/CPO clubs, or converted into "all hands" enlisted and officer facilities. Such changes began to be imposed following the congressionally-mandated end of Department of Defense budgetary subsidies for all such clubs in the 1990s and the subsequent need for these clubs to be financially self-sufficient. Further impacting the club system ashore for the Navy is the fact that most naval units deploy for extended periods (e.g., six to ten months) on a regular basis with, especially for shipboard personnel, requiring for senior enlisted personnel and commissioned officers to maintain concurrent membership in a ship's CPO Mess or officers' wardroom, respectively.


title: Mess

text: At sea aboard naval vessels, messing is still separate, with E-6 and below utilizing the ship's mess decks, E-7 through E-9 utilizing the ship's CPO mess, and commissioned officers being part of the wardroom. Certain large vessels (e.g., aircraft carriers, amphibious assault ships) may also include a first class mess for E-6, typically a separate dining area adjacent to the mess decks. This is considered a chance for future CPOs to learn how to be a part of a mess before they enter the CPO mess, often called by the sobriquet of "goat locker." Enlisted personnel normally receive all meals at what appears to be no cost, but in fact subsidize their meals through forfeiture of their Basic Allowance for Subsistence (BAS), also called "commuted rations," although chief petty officers may also have a mess "buy in" or monthly mess bill equivalent to the BAS. For those ships with embarked Marine Corps personnel, staff noncommissioned officers in the grades of E-7, E-8 and E-9 will also be part of the CPO Mess. Commissioned officers retain their BAS, a flat-rate allowance much smaller than the graduated by rank amount paid out to enlisted personnel; however, they must pay for all of their meals while afloat out of pocket. This usually entails a mess "buy in" as a member of the officers' mess and will typically have either a monthly mess bill or will purchase meals via some sort of debit card.


title: Mess

text: Social clubs on United States Air Force installations were at one time called Open Messes, even though most were known in vernacular as Officers Clubs or NCO clubs. Those for officers were able to utilize their initials as colorful acronyms, among the more well-known of which in the 1960s and 1970s were Zaragosa and Zweibrücken (ZOOM), Danang (DOOM), Ramstein (ROOM), and Korat Air Bases or Kirtland Air Force Base (KABOOM), Randolph AFB (Auger Inn) and Nellis AFB (Robin's Nest), with the nicknames usually ascribed to those facilities' casual bars versus the entire club.


title: Mess

text: At one time, each squadron had its club, and some flying squadrons continue to maintain a bar in the squadron facilities for officer and enlisted aircrew to this day, but most disappeared after World War II and the various Airmen's Clubs, Senior NCO Clubs and Officers' Clubs became facilities of a base rather than a unit. Most are now officially referred to as officer or enlisted clubs; the term "mess" or "officers' open mess" having largely disappeared from the Air Force lexicon. Though a few bases (usually major training bases) have separate Airmen's Clubs for junior enlisted and NCO Clubs for noncommissioned officers, this is no longer normally the case. Physically separate Officers' Clubs still exist at some installations; however, smaller Air Force installations may have one consolidated club with separate lounges. Membership is voluntary, though highly encouraged for senior NCOs and officers. Most NCO and Officers Clubs contain a sit-down restaurant in addition to social lounges, meeting/dining rooms, and bars.


title: Mess

text: Mess halls in the USAF, where unmarried junior enlisted residing in the dormitories are expected to eat, are officially referred to as "dining facilities," but are colloquially called "chow halls," although dining facility workers traditionally take offense at the term.


title: Mess

text: In the United States Marine Corps, enlisted dining facilities ashore are commonly referred to as 'galleys' or 'chow halls.' When embarked aboard naval vessels, enlisted Marines and NCOs in the rank of staff sergeant (E-6) and below use the same mess decks as sailors in the grade of petty officer first class (E-6) and below, while staff NCOs in the rank of gunnery sergeant (E-7) and above take meals in the chief petty officers (CPO) mess. Separate enlisted, NCO and officers clubs continue to exist at Marine Corps shore installations, following the Navy model of enlisted, CPO and officers clubs.


title: Mess

text: The United States Coast Guard follows the U.S. Navy model in terms of messing facilities afloat and ashore in terms of the demarcation of galleys for petty officer first class (E-6) and below, chief petty officer messes for chief petty officers (E-7) through master chief petty officers (E-9), and wardrooms for commissioned officers. The only exception is that, given its small size, there are very few Coast Guard clubs aboard Coast Guard shore installations and those that do exist are typically "all hands" facilities.


title: Shool

text: Shool () is a 1999 Indian Hindi-language action crime film directed by Eeshwar Nivas. Written and produced by Ram Gopal Varma, it portrays the politician-criminal nexus and the criminalization of politics in Bihar and its effect on the life of an honest police officer. It stars Manoj Bajpayee as Inspector Samar Pratap Singh and Sayaji Shinde as the borderline psychopath criminal-politician Bachhu Yadav, a character loosely based on politician turned criminal, Surajbhan Singh. The soundtrack consisting of "Main Aayi Hoon U.P. Bihar Lootne" featuring Shilpa Shetty became a chartbuster." The rights to this film are owned by Shah Rukh Khan's Red Chillies Entertainment.


title: Shool

text: Parts of the film were shot in Motihari, Bihar. The climax of the film was entirely shot at the state Legislative Assembly in Hyderabad. The film won the National Film Award for Best Feature Film in Hindi, and was screened at the International Film Festival of India, and the Toronto International Film Festival. "India Today" cited the film as the "Best Cop Movie" of the decade.


title: Shool

text: The film opens with a late night telephone call from Patna asking to speak to Bachchu Yadav (Sayaji Shinde), an MLA of the ruling political party in Bihar. His lackeys trace their boss to a prostitute's abode, where he receives the telephone and is informed that his party has selected another MLA for the ticket this time. He wastes no time, reaches the newly selected MLA candidate's home and pressures him to give up his nomination in lieu of money. When intimidation fails, his thugs stab the MLA-candidate under his supervision.


title: Shool

text: Meanwhile, Inspector Samar Pratap Singh (Manoj Bajpayee) arrives in Motihari, Bihar, where he has been transferred to, with his wife Manjari (Raveena Tandon) and daughter. At the railway station, he gets into a confrontation with a coolie (Rajpal Yadav). The two have a tiff on the payment of Rs. 30/- to be paid to the coolie for his services, which Singh refuses to pay, as he (rightfully) thinks he is being overcharged. As the situation goes to the verge of fisticuffs, a local police "hawaldaar" intervenes. Not knowing that Singh, too, is a police officer, the hawaldaar tries to manhandle Singh. Infuriated, Singh takes the matter to the police station to which he is posted. As Singh writes a complaint against the hawaldaar for harassing an innocent local (Singh), a sub-inspector, Hussain, intervenes. Hussain asks Singh to forgive the hawaldaar, to which Singh does not relent. Singh later learns that the Motihari police station runs according to Yadav's whims. Singh is an idealist who respects the constitution and the rule of law, and expects that everyone else should do the same. But no one follows the law in Motihari, especially the policemen who receive hafta (illicit weekly payments) from Yadav to do his bidding.


title: Shool

text: One day, the D.S.P. (Shrivallabh Vyas) asks Singh to break up a fight between two rival gangs and arrest the people who attacked some of Yadav's men. Singh investigates and finds out that Yadav's men are the real culprits. Among them are Sudhir Vinod (Nagesh Bhosle) and Lallan Singh (Yashpal Sharma), so Singh arrests them instead. When the D.S.P. orders Singh to release them, he refuses, saying that he has already registered the case. This is the first time Singh's superior learns of his real character and expresses concern over his future. Sub-inspector Hussain, who shamelessly admits to subjection to Yadav, declares that Singh won't last long in his current job if he continues in his ways. Singh sadly learns the limit of his official prowess, when the court releases Yadav's men.


title: Shool

text: Yadav demonstrates his limited education when he speaks in the Bihar Legislative Assembly against the construction of a hydro-electric dam on the river Ganges, as it would be "stealing" electricity from the water to the disadvantage of the farmers; he misquotes the famous political slogan "Jai Jawan Jai Kisan".


title: Shool

text: Singh finds himself alone in his fight and against the odds of a corrupt and rotten system. One day, while buying vegetables in the local market, he sees three young men sitting on a wall teasing passing girls by singing lewd Bhojpuri songs; when he confronts them, they react defiantly to Singh (who is in plainclothes). However, on learning that he is the S.H.O., two of them become defensive and tell him meekly that they are students of M.S. College, but the third declares proudly that he is the younger brother of Pranav Thakur, another influential politician, hoping that Singh will be impressed, but Singh retorts with a slap and forces him to apologise to the girls.


title: Shool

text: On his way home, Yadav decides to give an interview to a female journalist who boldly asks him if he is a murderer. Yadav, understandably, gets annoyed and tries to confuse and intimidate her, and upon failing to do so, simply asks her to get out of his car.


title: Shool

text: Yadav gets irritated by Singh's methods, particularity, because he arrested his men. He decides to annoy him and organises his own marriage anniversary. Singh reaches the scene and asks to see the required permission papers for operating loudspeakers late into the night. When no such official papers are produced, Singh seizes the music system and disrupts the party. Yadav confronts him and asks to be forgiven (in a patronising and satiric manner). The inebriated D.S.P., who is also present at the party, tries to cool Singh's tempers by telling him such rules are inconsequential in small villages. Singh refuses to yield, which angers the D.S.P. who gives Singh a direct order to let the matter go. Singh stands firm, and states that he will let the situation go only if given written orders. The following morning, the act of defiance by Singh causes a heated debate between Singh and the D.S.P., who, with the help of the corrupt sub-inspector Hussain, frames Singh for a physical attack on his senior. Tiwari (Vineet Kumar) tries to help Singh but in vain and Singh is suspended from his post.


title: Shool

text: Yadav and his men decide to land the final blow on Singh and finish him once and for all, with his goons passing disgustingly indecent comments towards Singh's daughter at a market, causing Singh to lose his temper and single-handedly beating them. One of the henchman attacks Singh with a heavy wooden club, but instead bludgeons Singh's daughter on her head, killing her.


title: Shool

text: When the badly injured Laljee goes to Yadav and tells him that Singh has beaten them badly, Yadav, who cares next to nothing even about his most loyal men, finds it a golden opportunity to accuse Singh. He immediately takes a shotgun from the wall and hits Laljee on the head forcefully enough to kill him, and then orders his henchmen to register a complaint that Laljee actually died because of the beating by Singh. The police waste no time and arrest Singh while he is still grieving over his daughter's dead body. Singh's parents come to help him, and his father (Virendra Saxena) pleads with Yadav to get him released. Yadav uses this situation to his advantage and gets Singh released by asking one of his henchmen to testify. When Singh realises that Yadav was behind his release, he insults Yadav.


title: Shool

text: A few days later, Singh's parents leave, and he has a big fight with his wife, who holds his idealism to blame for the quagmire they find themselves in, including their daughter's death. She asks him why he won't kill Yadav if he's as brave as he pretends to be. Singh tells her he's afraid for her sake, and leaves in a huff. Manjari tries to commit suicide with an overdose of sleeping pills. Singh's only true friend in town, the honest sub-inspector Tiwari, informs Singh about Manjari's suicide attempt and both rush to the hospital. Singh manages to speak a few sentences of comfort with her, where she absolves him of his guilt and asks him to avenge her and their daughter, before she dies.


title: Shool

text: Singh, having lost the woman he loved; feels he has lost everything and has nothing to live for anymore. He goes home, readies himself and wears his police uniform, visits the police station and snatches his service weapon in spite of sub-inspector Hussain's warning. Hussain pulls out his gun, but Singh kills him and makes way to Patna, where the state legislature is in session. He enters the well of the house, defying heavy security. Singh finds Yadav and drags him by his collar to the Speaker's dais. After an emotional appeal to members of parliament on the leadership crisis and criminalisation of politics, he shoots Yadav in the head, declares his patriotism and yells "Jai Hind" twice.


title: Franche-Comté

text: Franche-Comté (, ; ; Frainc-Comtou: "Fraintche-Comtè"; ; also ; ; all ) is a cultural and historical region of eastern France. It is composed of the modern departments of Doubs, Jura, Haute-Saône and the Territoire de Belfort. In 2016, its population was 1,180,397.


title: Franche-Comté

text: From 1956 to 2015, the Franche-Comté was a French administrative region. Since 1 January 2016, it has been part of the new region Bourgogne-Franche-Comté.


title: Franche-Comté

text: The region is named after the " (Free County of Burgundy), definitively separated from the region of Burgundy proper in the fifteenth century. In 2016, these two-halves of the historic Kingdom of Burgundy were reunited, as the region of Bourgogne-Franche-Comté. It is also the 6th biggest region in France. The name "Franche-Comté" is feminine because the word "comté" in the past was generally feminine, although today it is masculine.


title: Franche-Comté

text: The principal cities are the capital Besançon, Belfort and Montbéliard. Other important cities are Dole (the capital before the region was conquered by Louis XIV in the late seventeenth century), Vesoul (capital of Haute-Saône), Arbois (the "wine capital" of the Jura), and Lons-le-Saunier (the capital of Jura).


title: Franche-Comté

text: The region has been inhabited since the Paleolithic age and was occupied by the Gauls. It was then heavily settled by Germanic peoples during the Germanic migrations, most notably the Burgundians, who settled in the region after the Gauls had vacated the area. Later, it was part of the territory of the Alemanni in the fifth century, then the Kingdom of Burgundy from 457 to 534. The Burgundians adopted Orthodox Christianity, Christianizing the region. In 534, it became part of the Frankish kingdom. In 561 it was included in the Merovingian Kingdom of Burgundy under Guntram, the third son of Clotaire I. In 613, Clotaire II reunited the Frankish Kingdom under his rule, and the region remained a part of the Kingdom of Burgundy under the later Merovingians and Carolingians.