Minimum Wage Essay Example for Free

Minimum Wage Essay American workers will have a 1.75$ increase in their hourly wage by the end of 2015, as President Barack Obama recently called to raise the federal minimum wage from $7.25 an hour $9.00 an hour. This increase in the minimum wage of American citizen aims to help people with a low annual wage: cooks, employees of the janitorial industry and many others working these necessary menial occupations are set to benefit. The white house estimates that this measure will boost the wage of approximately 15 millions low-income workers. Raising the minimum wage, according to the White House press, will have some positive effect for low-income families; however, many companies are opposed to raising the minimum wage. A higher wage will have a direct impact on the cost of business. Some economists argue that higher minimum wage will result in an increased unemployment percentage. Although minimum wage laws can fix hourly pay, they cannot guarantee jobs. Employers are not willing to pay a worker more than the value of the additional product that he produces. For example, if a worker produces 4$ worth of goods per hour and because of the minimum wage he has to be paid 5.15$. Since he cost more than what he produces it makes it hard for him to find a job. At one point in the article, the President said that one of the best ways to get the economy going again is to put money in the pockets of people who work. (Lowrey)It is true that families with low income will earn more money: it is projected that a family that is earning $20,000 to $30,000 a year will see an additional $3,500 in their income. (Lowrey) This general positive outcome of increasing the minimum wage has led many law makers to wrongly assume that increasing the minimum wage is an effective way to fight  poverty. From the point of view of an economist, raising the minimum wage may increases the probability that a poor family will escape poverty through higher wages, but it does increase the probability of another family with average income will become poor as a result of minimum wage giving rise to inflation. It also decreases the proportion of families with income near the poverty line, suggesting that it more will be more difficult to escape poverty. We all know that if the minimum wage increases then the cost of living will inevitably increase as well as a result of inflation. Economists are against minimum wage laws because they create a price floor. In this case, a price floor is not the price that products can be sold for, but what price employers can spend on their employees. For non-economists, legislating a minimum wage is commonly seen as an effective way of giving raises to low-wage workers. Unfortunately it, like any other price floor, creates a surplus. In this case, the surplus is a larger than expected number of workers more of are willing to work in minimum-wage jobs than there are employers willing to hire at that wage. Economists think that there should not be any policies concerning wages: an employee should be paid what the employer thinks he/she deserves. Minimum wage increases make unskilled workers more expensive and therefore undesirable relative to all other factors of production. (Mankiw) For example, if skilled workers make 15$/hour and unskilled workers make three dollars an hour, skilled workers are five times as expensive as the unskilled. Imposing a minimum wage of five dollars an hour makes skilled workers relatively more attractive by making them only three times as expensive as unskilled workers. Another important characteristic of the policy to increase minimum wage that was not discussing in the article is that it may also negatively impact workers by changing how they are compensated. Benefits such as paid vacation, free room and board; inexpensive insurance and subsidized childcare are an important part of the total compensation for many low wageworkers. (Mankiw) When minimum wages rise, employers can control total compensation costs by cutting benefits; such is the case for the United States today. The employer always had to follow the minimum wage in order to pay their employee. The minimum wage should not be existent nowadays; the employer should have the choice to pay their employee based on their knowledge. An employee that knows more and produces more should have an higher hourly range. Sources: Textbook Mankiw, N. Gregory. Principles of Economics. 6th. Mason, OH, USA: 2012. Print. Website: Lowrey, Annie. Raising Minimum Wage Would Ease Income Gap but Carries Political Risks. New York Times. N.p., 13-02-2013. Web. 5 Oct 2013. .

Much Ado About Nothing Essay: The Character of Don John -- Much Ado Ab

The Character of Don John in Much Ado About Nothing  Ã‚     Ã‚   William Shakespeare's Much Ado About Nothing is a comedy in which he uses one of his more peculiar villains. The antagonist in this play is Don John, the bastard brother of Don Pedro. In this paper I will discuss the role of Don John as well as his motives and the character himself. I will also delve into Shakespeare's use of Don John as the antagonist. I will be comparing Don John to other characters in the play as well as to other villains in Shakespeare's works. While Don John does not spend a great deal of time on the stage in Much Ado About Nothing, he still plays a vital role in the plot of the play. The plan that he sets in motion is one of the two main stories within the play (the battle of wit between Beatrice and Benedict being the other). Don John, as I mentioned before, is the bastard brother of Don Pedro. His illegitimacy is one of the factors that makes him altogether vile and hateful. He is bitter because of his social standing and at the beginning of the play is directly bitter and jealous of Claudio. We might find some reasoning into why Don John hates Claudio by what he says when speaking to Barrachio and Conrade in the first act. When finding out about Don Pedro's plot to help Claudio win the hand of Hero, Don John says: "Come, come; let us thither: this may prove food to my displeasure. That young start up hath all the glory of my overthrow: if I can cross him any way, I bless myself every way." (Shakespeare 16) While Shakespeare never actually distinguishes specific motives for Don John's hatred of Claudio, we can infer one of two possibilities from his use of the word "overthrow". The overthrow he refers to could be a military overthr... ... in the face to Don John. The character Don John is not a very complicated character. He is not a character that gets very much time on the stage either. You cannot deny, however, that he is one of the most evil and twisted characters that Shakespeare has ever come up with. I think that Don John is the perfect villain in every aspect of the word. Works Cited Hunter, G.K.  Ã‚   William Shakespeare: The Later Comedies.  Ã‚   Great Brittian:   Ã‚  Langman's Green & Co. Ltd.  Ã‚   1962 Shakespeare, William.  Ã‚   Much Ado About Nothing.  Ã‚   Cambridge:  Ã‚   At the University Press   Ã‚   1962 Shakespeare, William.  Ã‚   Hamlet.  Ã‚   New York and London:  Ã‚   W.W. Norton & Co., Inc.  Ã‚   1963 Shkespeare, William.  Ã‚   Much Ado About Nothing.  Ã‚   New Haven:  Ã‚   Yale University Press  Ã‚   1917 Spivack, Bernard.  Ã‚   Shakespeare and the Allegory of Evil.  Ã‚   New York:  Ã‚   Columbia University Press  Ã‚   1958

Investigating Factors That Affect the Rate of Reaction

Investigating Factors that Affect the Rate of Reaction of the Decomposition of Hydrogen Peroxide Emilio Lanza Introduction- In this experiment, the rate of reaction, calculated in kPa sec-1, of the decomposition of hydrogen peroxide will be investigated to see how the change in concentration of hydrogen peroxide and the change in temperature affect the rate of reaction. The data will be collected by measuring the gas pressure. The product of Hydrogen Peroxide is oxygen in a gas state thus it is mandatory to use the gas pressure sensor.By calculating the difference of the gas pressure divided by the amount of time from the raw data collection it is able to find the rate of reaction of the decomposition of hydrogen peroxide. * Control Variable- 1mL of yeast (catalyst) is being used in every trial. The volume of H2O2 is always 4 mL, even though the concentration changes and the sizes and type of test tube was the same because it can change the pressure. * Independent Variable- Concentra tion of H2O2 (M) and the temperature (Â °C) * Dependent Variable- The rate of reaction of the decomposition of hydrogen peroxide > rate of reaction = ?Pressure (kPa)Time (sec) . * Research Question- it is needed to calculate the rate of reaction (kPa sec-1) of the decomposition of H2O2 to understand how different factors such as the change in concentration and the change in temperature of H2O2 affect the rate of reaction. Materials and Method- Materials: * 0. 5 M Yeast solution (the catalyst) – 15 mL * 45 mL of 3 % H2O2 solution * A thermometer * A computer with LoggerPro Program. * A Vernier computer interface * A Vernier Gas Pressure Sensor * A 1 liter beaker * A match to light up the bunsen burner * A tripod Two 10 mL test tubes * Two 10 mL pipette * Distilled water – 15 mL * A matt/cover that is fire resistant * 700 mL of room temperature water from a sink * A one-hole rubber stopper with stem * Two test tube holders * Two 10 mL graduated cylinders * A bunsen burn er * Two solid rubber stopper * Plastic tubing containing two Luer-lock connectors * A one-hole rubber stopper with stem * A test tube rack Procedure: Part 1 of the experiment: Decomposing 3 % of H2O2 solution with 0. 5 Yeast at about 30Â °C 1. Take the 1-liter beaker and add 700 mL of room temperature water.Take the tripod, place a matt/cover that is fire resistant on top of the tripod and onto the matt/cover place the 1-liter beaker that has been filled up with 700 mL of room temperature water from a sink. 2. First hook the rubber tube from the Bunsen burner to a gas source, then take a match and turn on the gas source. Once the gas is on light the match and then light the bunsen burner. (MAKE SURE TO NOT BURN YOURSELF)!! 3. Place the lit bunsen burner underneath the tripod so it can begin to heat the 1 liter beaker with the 700 mL of room temperature water from the sink. . Insert a thermometer into the 1 liter beaker that is being heated and adjust the flame of the bunsen burner so it will heat the water to a temperature of about 30Â °C. 5. Take the 10 mL pipette and the 10 mL-graduated cylinder use the pipette and transfer 4 mL of H2O2 and using a 10 mL pipette transfer 4 mL of H2O2 from a container into the 10 mL graduated cylinder. 6. Take a 10 mL test tube and add fill 4 mL of H2O2 from the 10 mL graduated cylinder into the 10 mL test tube. Once that is done, take a rubber stopper and seal the 10 mL test tube containing the H2O2.Use the test tube holder to hold the test tube into the 1 liter beaker the is being heated to a temperature of about 30Â °C. Make sure that the majority of the test tube is submerged in water. 7. Using the other 10 mL pipette, transfer 1 mL of 0. 5 M Yeast into the other 10 mL graduated cylinder. From this graduated cylinder, transfer the 0. 5 M Yeast to a new 10 mL test tube; seal the test tube with a new solid rubber stopper. With the other test tube holder, place this test tube containing 1 mL of 0. M Yeast into 1 liter be aker that is currently being heated to a temperature of about 30Â °C. 8. Turn on a computer and start the LoggerPro Program. 9. Connect the Gas Pressure Senor to Channel 1of the Vernier computer interface and with the correct cable attach the Vernier computer interface to the computer. 10. Take the plastic tubing with the Leur-lock connectors at either end of the tubing, connect the tubing to the base on the one-hole rubber stopper and the other end of the plastic tubing, it must be connected to the white stem on the end of the Gas Pressure Sensor called a Luer-lock. MAKE SURE THE PLASTIC TUBING TIGHTLY SECURED OR THE GAS WILL ESCAPE AND IT WILL LEAD IT IN ACCURATE READINGS). 11. Once the LoggerPro Program has been opened make sure that the label on the x-axis is time in seconds and that the units on the y-axis is pressure in kPa before collecting the data. 12. Leave the test tubes in the water bath for at least two minutes so that the solutions in the test tube have a temperature of around 30Â °C. Once the water is about 30Â °C, record this temperature into a data table. When two minutes have passed by, commence the reaction and collect the pressure data.Remove both test tubes from the water by holding onto the test tube holder, place them in a test tube rack and remove each seal from the test tubes. Transfer the yeast solution from its test tube into the test tube containing H2O2 solution and shake lightly to mix the two solutions together. 13. As quick as possible seal the test tube with the one-hole stopper connected to the Gas Pressure Sensor and place the test tube back into the water by holding the test tube with the test tube holder. Next click collect data on the LoggerPro Program to begin collecting data. THE LAST TWO STEPS ARE CRUCIAL AND MUSTBE DONE AS QUICK AS POSSIBLE TO AVOID ANY EXTERNAL INFLUENCES). 14. It is needed to collect the data for three minutes once three minutes is up, carefully remove the test tube from the water by holding onto the test tube holder and set it in the test tube rack. Next slowly and carefully begin to tale out the stopper from the test tube allowing the gas pressure to escape. 15. Store the results from the first trial by selecting Store Latest Run from the Experiment menu. After doing this a table of data and the graph will be saved.Then make sure to clean and trash the solution that is in the test tube. Repeat the first part another two more time so you can have three trials in total. Then print the graph and the full data table from each trial. Part 2 of the experiment: Decomposing 1. 5 % of H2O2 solution with 0. 5 Yeast at about 30Â °C 1. Take a 10 mL graduated cylinder and using a 10 mL pipette (make sure you are using the same pipette for the H2O2 as in previous trials and don’t interchange this pipette for the one being used with Yeast) fill 2 mL of H2O2 from the same container like it was done in part 1 into the 10 mL graduated cylinder.Once that is done insert 2 mL of distil led water as well into the graduated cylinder containing H2O2. 2. Now grab the 10 mL test tube (which has been thoroughly washed with water) and insert the 4 mL of H2O2 which has been mixed with the distilled water from the 10 mL graduated cylinder into the 10 mL test tube. Then take the 10 mL test tube and with the H2O2 seal it with a rubber stopper. Use the test tube holder so you can place the test tube in the 1 liter beaker that is being heated to 30Â °C. Be sure that the test tube is deep enough in the 1 liter beaker. . Using the other 10 mL pipette, take the 1 mL of 0. 5 M yeast and our it into the other 10 mL graduated cylinder. Then grab the graduated cylinder and put the 0. 5 M yeast to a new 10 mL test tube; close the test tube so no air comes in with a new rubber stopper. With the other test tube holder, place this test tube containing 1 mL of 0. 5 M KI into 1 liter beaker that is currently being heated to a temperature of about 30Â °C. Repeat steps 13-18 from part I. P art 3 of the experiment: Decomposing 0. 75 % of H2O2 solution with 0. 5 Yeast at about 30Â °C 1.Take a 10 mL graduated cylinder and using a 10 mL pipette (make sure you are using the same pipette for the H2O2 as in previous trials and don’t interchange this pipette for the one being used with KI) transfer 1 mL of H2O2 from the same container like in part I into the 10 mL graduated cylinder. Add 3 mL of distilled water into the graduated cylinder containing H2O2. Mix the solution gently. 2. Take a 10 mL test tube (which has been cleaned after previous trials) and transfer 4 mL of H2O2 mixed with distilled water from the 10 mL graduated cylinder into the 10 mL test tube.Then seal the 10 mL test tube containing the H2O2 with a solid rubber stopper. With one of the test tube holders, place the test tube into the 1 liter beaker that is currently being heated to a temperature of about 30Â °C. Make sure that the majority of the test tube is submerged in water. 3. Using the other 1 0 mL pipette, transfer 1 mL of 0. 5 M yeast into the other 10 mL graduated cylinder. From this graduated cylinder, transfer the 0. 5 M yeast to a new 10 mL test tube; seal the test tube with a new solid rubber stopper.With the other test tube holder, place this test tube containing 1 mL of 0. 5 M yeast into 1 liter beaker that is currently being heated to a temperature of about 30Â °C. Repeat steps 13-15 from part 1. Part 4 of the experiment: Decomposing 3. 0 % of H2O2 solution with 0. 5 Yeast at about 35Â °C 1. For this part repeat the steps 6-7 and 13-15 from part 1. The only thing that is needed to be changed is that the water needs to be about 35Â °C. Part 5 of the experiment: Decomposing 3. 0 % of H2O2 solution with 0. 5 Yeast at about 40Â °C 1. For part 5 redo the steps 6-7 and 13-15 from part 1.The only thing that is needed to be changed is that the water needs to be about 40Â °C. Steps once all the five parts of the experiment are complete 1. Now look at the data table that has been filled in for each trial from each and calculate the average reaction rate (kPa sec-1) of the decomposition of H2O2 that occurred over 3 minutes for each part and put it into the analysis table 2. Insert the concentration of H2O2 and yeast from each part into the analysis table as well. 3. Make sure to find the average temperature (Â °C) and include it in the analysis table. . Then compare and contrast the different effects the rate o reaction caused by the change in concentration of H2O2 and in the change of temperature. (The data table is an example of the data table that will be printed from the computer after each trial and part is done from LoggerPro Progam. The only thing is that it will record the gas pressure until 3 minutes. Again only an example how it should look like). The Gas Pressure from the Decomposition of H2O2 After Every Second| Time (sec)| Gas Pressure (kPa)| 1| | 2| | 3| | 4| | 5| | 6| | 7| | 8| | | | 10| | Data Analysis Table for the Decompositio n of H2O2| Part #| Average Temperature (Â °C)| Average Rate of Reaction (kPa sec-1)| Concentration of H2O2 in %| Concentration of Yeast (M)| Part 1| | | | | Part 2| | | | | Part 3| | | | | Part 4| | | | | Part 5| | | | | The Temperature (Â °C) of the Water During Each Part of the Lab and Each Trial | Parts of Experiments| Trial 1| Trial 2| Trial 3| Part 1 Temperature (Â °C)| | | | Part 2 Temperature (Â °C)| | | | Part 3 Temperature (Â °C)| | | | Part 4 Temperature(Â °C)| | | | Part 5 Temperature (Â °C)| | | |

The transfer of shares - Free Essay Example

Sample details Pages: 5 Words: 1420 Downloads: 9 Date added: 2017/06/26 Category Law Essay Type Case study Did you like this example? Question 1 The relevant provisions in the articles of association of Treeng Ltd (à ¢Ã¢â€š ¬Ã…“Treengà ¢Ã¢â€š ¬Ã‚ ) are twofold. First, the directors are empowered to refuse to register a transfer of shares, and it seems that they may exercise this power in their absolute discretion. At common law, however, such power must be exercised à ¢Ã¢â€š ¬Ã…“bona fide in what they consider à ¢Ã¢â€š ¬Ã¢â‚¬Å" not what a court may consider à ¢Ã¢â€š ¬Ã¢â‚¬Å" is in the interests of the companyà ¢Ã¢â€š ¬Ã‚ [1] and the decision to refuse to register a transfer must be a positive act taken by the board, not a mere failure to approve the registration[2], but the directors do not need to give reasons for their refusal[3]. Don’t waste time! Our writers will create an original "The transfer of shares" essay for you Create order Secondly, the articles provide that the directors must notify the transferee of their refusal within two months. This is consistent with the requirement imposed by section 183(5) of the Companies Act 1985 (à ¢Ã¢â€š ¬Ã…“CA 1985à ¢Ã¢â€š ¬Ã‚ ), which also provides for a penalty if this requirement is breached (section 183(6) and Schedule 24 CA 1985). These provisions are currently still in force, and will be effectively recast in sections 771(1)(b), (3) and (4) of the Companies Act 2006 (à ¢Ã¢â€š ¬Ã…“CA 2006à ¢Ã¢â€š ¬Ã‚ ) when the latter provisions come into force. The articles appear to be silent on the issue of pre-emption rights of other members, and the issue will therefore not be considered further. Arnold lodged the transfer of the shares to Bill with Treeng immediately after its execution four months ago, but the transfer has not been registered by the company and Bill has not been notified of any decision by Treengà ¢Ã¢â€š ¬Ã¢â€ž ¢s directors. The transfer of shares is not complete until Bill is registered as the new owner of the shares in the register of members, although Bill may have an equitable interest in the shares if he purchased them[4]. However, the directorsà ¢Ã¢â€š ¬Ã¢â€ž ¢ right of refusal must be exercised within a reasonable time, and in any event within the statutory two months[5]. As four months have now elapsed, if the directors have not taken a positive decision to refuse to register the transfer, they will have lost the right to do so[6], and Bill therefore has a right to be registered as a member. He should apply to the court to have the register rectified under section 359 CA 1985 and should serve a notice on Treeng for a share certificate to be issued as required by sections 185(1) and (5) and Schedule 24 CA 1985. There may be an obstacle for Bill if the directors of Treeng can show that they in fact decided to refuse to register the transfer within two months of the transfer form being lodged with the c ompany, and then simply failed to notify Bill of their decision. In Popley v Planarrive Ltd[7] Laddie J held that such default will make the relevant officers liable under section 183(6) CA 1985, but will not in itself affect the validity of the refusal. However, Laddie J went on to suggest that there may be circumstances in which the delay in notification is such that the company ought to be estopped from relying on its refusal to register[8]. In my view it is likely that even if the directors did decide to refuse to register the transfer within the prescribed two months, Bill may persuasively argue that the delay in notifying him is such[9] that the company ought to be estopped from relying on the decision and that the register ought to be rectified and the share certificate issued as discussed above. Question 2 As Henryà ¢Ã¢â€š ¬Ã¢â€ž ¢s signature on the transfer form is forged, the instrument is void and there is therefore no transfer of his shares[10]. This means that Henry has the right under section 359 CA 1985 to request that the company rectify its register of members by restoring his name in place of Malcolmà ¢Ã¢â€š ¬Ã¢â€ž ¢s. This will be the case even if there is evidence that Henryà ¢Ã¢â€š ¬Ã¢â€ž ¢s own conduct gave Bernard the opportunity to commit the fraud[11] (and indeed it appears that Henryà ¢Ã¢â€š ¬Ã¢â€ž ¢s carelessness gave Bernard the opportunity to steal the share certificate and then commit the fraud). This strict position will of course adversely affect Malcolm, who is likely to have paid Bernard for the shares. In addition, there will be little point in Malcolm seeking to pursue a claim against Bernard, as the latter has in all likelihood disappeared with the money. Malcolm will want to rely on the doctrine of estoppel by share certificate. The doctrine provides that where a company has issued a share certificate (which contains a statement that the transferor is the registered holder of the shares) and a transferee has subsequently relied on the certificate to his detriment as proof that the transferor did in fact own the shares, the transferee may claim an indemnity from the company if it later transpires that the share certificate was in fact false and that the transferor did not own the shares[12]. The company, on the other hand, may in turn claim an indemnity against the party who lodged the forged instrument which led to the issue of the false certificate, even if such party had no knowledge that the instrument was forged[13]. In the present scenario, a valid share certificate was issued by the company to Henry. There is no suggestion that Bernard fraudulently transferred the shares to himself and then requested a certificate in his own name to be issued before purportedly transferring the shares to Malcolm. Therefore, Malcolm will have relied on the valid share certificate as evidence that the shares were owned by Henry, and will then have acted on the erroneous assumption that Berna rd was in fact Henry. It follows that the doctrine of estoppel by share certificate will not assist Malcolm in these circumstances, as the certificate relied on by Malcolm was in fact a perfectly valid one. As Malcolm will not be able to seek an indemnity from the company, there will be no scope for the company to seek an indemnity from the party who lodged the forged instrument, although rather interestingly in these circumstances that party would be Malcolm himself, creating a rather odd circularity. Consequently, it appears that Henryà ¢Ã¢â€š ¬Ã¢â€ž ¢s name will be reinstated and Malcolm will have no remedy against Bernard or the company. Although this approach is somewhat harsh in relation to Malcolm, it appears that the rationale underlying it is that the transferees or their brokers are in a better position to asses whether the purported transferors are rogues than companies, who generally issue share certificates as a mere administrative procedure. The situation wou ld be different if Malcolm had meanwhile transferred his shares to Nadia, whose name now appeared in the register of members. Henry would again be able to insist on the reinstatement of his name in the register in place of Nadiaà ¢Ã¢â€š ¬Ã¢â€ž ¢s, but Nadia could argue that she had relied on the share certificate issued to Malcolm as evidence of Malcolmà ¢Ã¢â€š ¬Ã¢â€ž ¢s ownership of the shares. As such certificate is in fact false, Nadia would be able to seek compensation from the company, which in turn would be able to seek compensation from Malcolm who, though unknowingly, lodged the forged transfer form in the first place[14]. BIBLIOGRAPHY Barber, Company Law, 4th ed., London, Old Bailey Press, 2003 Davies, Gower and Daviesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Principles of Modern Company Law, 7th ed., London, Sweet Maxwell, 2003 Mayson, French Ryan, Company Law, 23rd ed., Oxford University Press, 2006 Sealy, Cases and Materials in Company Law, 7th ed., London, LexisNexis UK, 20 01 Shepherd, Company Law: 150 Leading Cases, 3rd ed., London, Old Bailey Press, 2004 Hardoon v Belilios [1901] AC 118 Popley v Planarrive Ltd [1997] 1 BCLC 8 Re Hackney Pavilion Ltd [1924] 1 Ch 276 Re Smith and Fawcett Ltd [1942] Ch 304 Re Swaledale Cleaners Ltd [1968] 1 WLR 1710 Royal Bank of Scotland plc v Sandstone Properties Ltd [1998] 2 BCLC 429 Simms v Anglo-American Telegraph Co (1879) 5 QBD 188 Welch v Bank of England [1955] Ch 508 1 Footnotes [1] Re Smith and Fawcett Ltd [1942] Ch 304, per Lord Green MR at 306. [2] Re Hackney Pavilion Ltd [1924] 1 Ch 276. [3] This position will be changed when sections 771(1)(b) and (2) of the Companies Act 2006 come into force. [4] Hardoon v Belilios [1901] AC 118. [5] Re Swaledale Cleaners Ltd [1968] 1 WLR 1710. [6] Ibid. [7] [1997] 1 BCLC 8. [8] This point was not argued by either counsel in the case, and is therefore strictly obiter. [9] The delay will be of at least two months, as the decision must have been taken within two months from the lodging of the transfer: Re Swaledale Cleaners Ltd, cf. note 5 above. [10] Simms v Anglo-American Telegraph Co (1879) 5 QBD 188. [11] Welch v Bank of England [1955] Ch 508. [12] It should be noted that under section 186(1) CA 1985 a share certificate is merely à ¢Ã¢â€š ¬Ã…“prima facie evidenceà ¢Ã¢â€š ¬Ã‚  of a memberà ¢Ã¢â€š ¬Ã¢â€ž ¢s title to the shares. [13] Royal Bank of Scotland plc v Sandstone Prop erties Ltd [1998] 2 BCLC 429. [14] Ibid.