Decision of the House of Lords in Street V Mountford

Decision of the House of Lords in Street V Mountford â€Å"The decision of the House of Lords in Street v Mountford in 1985 represented a sea-change in the approach of the courts† (Smith R, Property Law 6th edition (2009) p. 354, Longman Press). Discuss in the context of the courts approach to the distinction between leases and licences. Introduction Many cases prior to Street v Mountford[1] had attempted to identify the difference between a right to ‘possess’ land and a personal right to ‘occupy’ land. Lord Denning explained the difference as ‘the nature and quality of the occupancy.’[2] In other words, ‘a legal right of exclusive possession of the land for a term’[3] would constitute a lease, and a mere permission to use land would amount to a licence. The ‘exclusive possession’ test established by the House of Lords in Street v Mountford, per Lord Templeman, was that an occupier would not be a tenant if he had no exclusive ‘possession’ for a ‘certain’ duration. This case has now been regarded as having marked a ‘sea-change’ in land law. The distinctions to be drawn between leases and licences There are certain reasons why the courts have sought to distinguish between licences and leases. Different statutory protections exist for both. The real problem, however, is in how the courts have attempted to draw the line between leases and licences, particularly in the light of the exclusive possession test[4]. The court’s first concern would be that the term ‘licence’ is too broad it covers almost all types of permission. When we use the term ‘licence’ in relation to land, however, we mean, not merely a personal right to occupy the land but also, a right to use the land in any way. However, such right can be distinguished from a proprietary right[5]. In licences, the individual holding the licence (i.e. the licensee) has, in general, no right to exclude others from the land (including the landowner). A difficulty therefore arises in circumstances where the licensee has the full right (including where s/he has been granted exclusive possession) t o occupy the land. In this context, as shall be discussed below, Lord Denning stated that exclusive possession does not necessarily equate to the grant of a lease, particularly if the parties did not intend to create a tenancy. Although the test in distinguishing between licences and leases does assist in practice, such test is not as straightforward (at least in theory) as one might first expect. Difficulties in distinguishing between leases and licences According to Lord Templeman, the exclusive possession test is conclusive: a person granted exclusive possession must have a lease. However, it does not necessarily mean that one has a lease even though the courts have tended to adopt this approach. Furthermore, it is not easy to apply the exclusive possession test in practice. The first problem for the courts to consider would be when the grant of a right to ‘occupy’ land should amount to a grant of a lease for ‘possession’. The same problem also arises in the definition of ‘certain’ duration. An underlying issue arising out of the first problem would be for the courts to distinguish between ‘possession’ and ‘occupation’[6]. The meaning of ‘possession’ and ‘occupation’ are not exactly the same. The inconsistent use of the term ‘occupation’ and the term ‘possession’ in the Street v Mountford judgment somewhat confused the understanding of the concepts of ‘exclusive occupation’ and ‘exclusive possession’. Lord Templeman also failed to distinguish whether those concepts were statements of legal entitlement or statements of fact. Nevertheless, according to the judgment read as a whole, the term ‘occupation’ should refer to the fact that an occupier merely enjoys the occupation of the land. The term ‘possession’ should refer to those situations where the occupier has the right to enjoy land and exclude all others (including the landowner) from the la nd. Lord Templeman sought to distinguish leases and licences in the following ways: ‘Occupation’ is not sufficient for the occupier to grant a lease; ‘exclusive possession’ is essential. No lease is granted when there is no exclusive possession. Even though an occupier has exclusive possession the landowner and the occupier may have no intention to create a legal relationship or the intention may be negatived by the facts of the case those occupations should not amount to the grant of lease. The latter factor is sufficient to distinguish between lodgers and tenants in circumstances such as renting a hotel room. In the absence of those negative factors, the possession held by the occupier should amount to ‘exclusive possession’. When the occupier has been granted ‘exclusive possession’ for a certain period and at a rent, the grant of a lease should be presumed. Although the occupier has exclusive possession and the right to exclude all others from the land, the right granted might be considered to be something other than a lease such as ‘fee simple ownership’. Prior Street v Mountford, the element of exclusive possession was not a necessary requirement to be considered.[7] However, Lord Templeman confirmed that the consideration of exclusive possession was necessary and conclusive. He further developed the principle expounded by Lord Denning: ‘the nature and the quality’ of occupation is essential to determining whether the occupation is a lease or a licence.[8] Lord Denning stated that although exclusive possession could be considered as the main element in deciding whether an occupier has granted a lease, it does not necessarily mean that an occupier who grants exclusive possession is not necessarily granting a lease. Nevertheless, a person in ‘occupation’ has no tenancy if he has no exclusive right in the land. Lord Templeman explained that the intention of creating a legal relationship is also important to distinguishing between a lease and a licence. However, the subjective intention between the occupier and landowner is irrelevant the court should look at the objective agreement, i.e. whether the parties intended to create a legal relationship. First, the parties cannot assume that the label attached to the agreement will be conclusive.[9] Secondly, the parties’ agreement cannot act as a device in order to disguise[10] the grant of a tenancy.[11] Thirdly, specific provisions within the agreement may be ignored by the court if the surrounding circumstances suggest that those provisions could not have been intended to form part of the agreement.[12] It has been held that a time limitation may apply (in this case between 10:30am to noon) in respect of exclusion of persons from a property.[13] Finally, if the occupier shares occupation with others, the court may read the relevant agreements together and treat those agreements as one transaction, even if the facts suggest that those occupiers’ relationships are interdependent.[14] The House of Lords reaffirmed these principles in the latter case Burrows v Brent LBC[15]. In that case, the landowner granted a possession order against the tenant for unpaid rent. They agreed temporarily not enforce the order and to allow the tenant to remain in occupation if she paid a sum equivalent to the rent due. Applying those principles to this situation, it was held that the parties had not intended to create a legal relationship, and the tenant therefore was considered a ‘tolerated trespasser’. Lord Millett[16] also confirmed the principle that exclusive possession on its own is not sufficient for the granting of a lease, but that occupation with the identification of a legal relationship between the occupier and the landlord is an essential consideration. Lord Millett therefore regarded Street v Mountford[17] as a significant authority for the proposition that a person in ‘occupation’ or ‘possession’ may be regarded as merely a licensee if there is no legal relationship. Notwithstanding the fact that the debate about the definition of ‘legal relationship’ will be ongoing, the differences between leases and licences may be distinguished by the degree of ‘possession’. If someone who is purely holding a personal right to occupy land without a legal relationship, then such right will, in most cases, be a licence. Alternatively, if someone grants a right to exclude all others from the land in question, including the landlord, for a certain period of time, then such right may be called a lease. The ‘terminology’ problem of the words ‘possession’ and ‘occupation’ appear to have been solved by the cases which were decided after Street v Mountford[18]. The debate surrounding the meaning to be given to ‘certain’ duration, however, still remains alive. Lord Denning posed: what would the court do if the occupier has been granted exclusive possession of land without certain duration?[19] In law, if a landlord grants an occupier (who pays rent) exclusive possession of a property without certainty of duration, the occupier will have a periodic tenancy (demonstrated by the payment of a periodic rent) rather than a licence.[20] This case reaffirmed that the element of ‘exclusive possession’ is the most important consideration to the granting of a lease. Nevertheless, the distinction between the tenant (leaseholder) and the lodger (licensee) is very significant[21]. Case law has established that the distinction will arise from the fact that an agreement might allow a landowner to exercise unrestricted rights to use or access property, and not simply ‘from the provision that the landowner provides service to such property’.[22] An additional consideration for the courts, established by one particular case, was to examine the extent of the right which the landowner actually has to exercise.[23] By reference to that approach, it will become clear whether there is a tenant or a lodger to property.[24] Another significant impact which Street v Mountford[25] has made in the context of litigation has been in relation to the duties of local authorities to provide accommodation for the homeless under the Housing Act 1985 (now Part VII of the Housing Act 1996). The Court of Appeal has held that although an occupier has been granted exclusive possession, a local authority might have had provided accommodation pursuant to its statutory duties towards the homeless which will have the effect of negating the intention of creating a legal relationship between the parties.[26] However, if the accommodation was provided by a housing association or an organisation other than the local authority (even on referral from the local authority), the background of homelessness will not negative the intention of creating a tenancy as such an association or organisation does not exercise any statutory duty.[27] Therefore, the House of Lords affirmed that the duties of local authority were held to negative the intention of creating a lease even though the occupier was granted an exclusive possession of the property.[28] In the case Burton v London and Quadrant Housing Trust, since the agreement in question stated that the housing trust had no legal title to the property and the parties had attempted to create a licence rather than a lease, the Court of Appeal held that there was no lease because the housing trust had no legal title to the property. However, the House of Lords found that legal title was not relevant.[29] Nonetheless, the distinction between licence and lease in this context (under statutory duty) has been reduced by the Housing Act 1996, section 216(3), Schedule 17, para 3. Having regard to the Housing Act 1996, the Court of Appeal held that granting exclusive possession under the statute would not amount to the creation of a lease. This rule also applies to the relationship between beneficiaries and trustees the trustee has the power to grant the right, but the grant of a lease may intrude upon the trustees’ duties.[30] Conclusion Although the rules of Street v Mountford[31] apply in cases of residential occupation, certain principles deriving from it such as the distinction to be drawn between ‘lodger’ and ‘tenant’ may not be applicable in certain circumstances. The basic elements of ‘exclusive possession’ and ‘the nature and quality’ test will, however, be applicable in the commercial occupation context. Nevertheless, we should note that Street v Mountford[32] was a case of a single occupier. Multiple occupation may, therefore, lead to a more complicated situation, which Lord Templeman has not discussed. (2,333 words) Bibliography Texts Gravells N P, Land Law: Text and Materials (1999) Street Maxwell, London Dixon M, Principles of Land Law (2002) Cavendish Publishing Ltd, London Oakley A J, Megarry’s Manual of the Law of Real Property (2002) Street Maxwell, London Clarke A and Kohler P, Property Law Commentary and Materials (2005) Cambridge University Press, Cambridge Articles Wilkinson H, The lease licence distinction. Again? (2001) NLJ Pawlowski M, Contractual licences, personal tenancies and tenancies at will (2001) L T Review 2001, 5(6), 117-118 Colbey R, Detecting a sham (2001) NLJ Morgan J, The changing meaning of ‘dwelling-house’ (2002) CLJ 61(2), 312 Grundy N and Joss N, Landlord and tenant update (2006) SJ 805 Peachey L, Elements of a tenancy assured and assured shortholds (2007) HLM 14 5(5) Cases Errington v Errington and Wood [1952] 1 KB 290 Radaich v Smith (1959) 101 CLR 209 at 222 Marchant v Charters [1977] 3 All ER 918 Street v Mountford [1985] AC 825 Markou v Da Silvaesa (1986) P CR 204 Brooker Settled Estates Ltd v Ayers (1987) 54 P CR 165 AG Securities v Vaughan (1988) 56 P CR 168 Hadjiloucas v Crean [1988] 1 WLR 1006 Ogwr BC v Dykes [1989] 1 WLR 295 Aslan v Murphy (No. 1) [1990] 1 WLR 766 Antoniades v Villiers [1990] 1 AC 417 Duke v Wynne [1990] 1 WLR 766 Family Housing Association v Jones [1990] 1 WLR 779 Prudential Assurance Co. Ltd v London Residuary Body [1992] 2 AC 386 Westminster City Council v Clarke [1992] 2 AC 288 Burrows v Brent LBC [1996] 1 WLR 1448 Gray v Taylor [1998] 1 WLR 1093 Family Housing Association v Jones [1999] 3 WLR 150 Ramnarace v Lutchman [2001] UKPC 25 1 Footnotes [1] Street v Mountford [1985] AC 825 [2] Marchant v Charters [1977] 3 All ER 918 [3] Radaich v Smith (1959) 101 CLR 209 at 222 [4] The lease – licence distinction. Again? (2001) NLJ [5] Contractual licences, personal tenancies and tenancies at will (2001) L T Review 5(6), 116-118 [6] Elements of a tenancy assured and assured shortholds (2007) HLM 14 5(5) [7] Hadjiloucas v Crean [1988] 1 WLR 1006 [8] Errington v Errington and Wood [1952] 1 KB 290 [9] Duke v Wynne [1990] 1 WLR 766 [10] Detecting a sham (2001) NLJ [11] Ibid. [12] Aslan v Murphy (No. 1) [1990] 1 WLR 766 [13] Antoniades v Villiers [1990] 1 AC 417 [14] AG Securities v Vaughan (1988) 56 P CR 168 [15] Burrows v Brent LBC [1996] 1 WLR 1448 [16] Ramnarace v Lutchman [2001] UKPC 25 [17] Ibid. [18] Ibid. [19] Ibid. [20] Prudential Assurance Co. Ltd v London Residuary Body [1992] 2 AC 386 [21] The changing meaning of ‘dwelling-house’ (2002) CLJ 61(2), 312 [22] Markou v Da Silvaesa (1986) P CR 204 [23] Ibid. [24] Brooker Settled Estates Ltd v Ayers (1987) 54 P CR 165 [25] Ibid. [26] Ogwr BC v Dykes [1989] 1 WLR 295 [27] Family Housing Association v Jones [1990] 1 WLR 779 [28] Westminster City Council v Clarke [1992] 2 AC 288 [29] Family Housing Association v Jones [1999] 3 WLR 150 [30] Gray v Taylor [1998] 1 WLR 1093 [31] Ibid. [32] Ibid.

European Diplomatic History Essay

Introduction Different groups of people have different views about the First World War. For some, it was a crisis for the whole world whereas others say that it was the biggest historical crisis. Military differences which started from the year 1914 to the year 1918 led to the war against Russia and ultimately turned into a global war involving 32 nations. The Allied Forces comprised of twenty eight nations including France, Italy, Russia, United States, Great Britain, etc. It was a one side battle against the combined forces named Central Power having Turkey, Germany, Bulgaria and Austria-Hungary. Reasons for the First World War included strong nationalism that influenced Europe from 19th century to 20th century. The second important reason was competition among nations in their economic values. Rapid increment in armed forces especially after 1871 was another reason. Moreover, Germany came out as the great world power. The only idea behind the war was that people of same language, political ideas and culture should have an independent country. This idea of national self-determination was mostly ignored by the generations of rulers and forces who opposed the concept of self-determination and dominated the Congress of Vienna in the year 1815 to settle European affairs. Strong revolutions and nationalist movements over a few decades totally nullified congress policies when Belgium snatched independence from Netherlands in the year 1831. Revolutionary movements also played a vital role in the unification of Italy and Germany in the years 1861 and 1871 respectively. â€Å"The First World War was always known to Europeans and Americans as the Great War.† (McCarthy, pg 349) Young Turks Revolution In July 1908, Junior Officers of the Second and the Third Army who were placed in Macedonia and Edirne went against their officers and demanded restoration of the 1876 Ottoman constitution. These Young Turks were members of CUP (Committee of Union and Progress) and they began their rebellion. The resulting revolution changed the history of Turkey. In 1902 and 1907, Young Turks’ congresses were held in Paris in which two ideas emerged and built their groups eventually. Ahmet RÄ ±za was the leader of Young Turks and the son of a member in the first Ottoman parliament. His group supported the ideology of a secular nation for those Turks who were pursuing scientific advancement and reasonable progress of Europe. They were in support of nationalist economic policies and resisted American interference in Europe. The other group was in favor of Prince Sabahettin (member of the Ottoman dynasty). He was an economic, liberal Ottoman and wanted to establish a unified and multi religious empire. He believed in decentralization. He gave importance to foreign capital for the economic growth of the empire. He confessed the role of Islam in modernization of the Ottoman Empire.   â€Å"It would seem impossible one man could have so many different roles and carry out so many different functions which would normally require prolonged specialization, but this was possible in the early days of the Young Turks Revolution† (Karpat, pg 840). Young Turk liberals were in favor of the ideas of Prince Sabahettin. There were religious conservatives, including many ulema and dervish leaders, who argued that the revolution had fallen down from Shariah regime. A religious extremist organization called Muhammadan Union took troops of the First Army with groups of many other people for demonstrations in front of the parliament to restore Shariah and terminate unionist officers from the ministry. Liberals underestimated the intensity of religious anger against unionist and eventually found the whole situation uncontrollable due to which the Unionists fled. These kinds of violence and demonstrations took place in other parts of the empire too and thousands of Americans were killed. In Macedonia, the Unionists regrouped due to the CUP strength in the area and units of the Third Army regulated to take position outside Istanbul under the leadership of Commander Mahmud Åževket PaÅŸa. On 24 April 1909, they occupied the capital in an army action. Later on in the mid of May, the attempted counterrevolution came to an end due to public executions. After the elimination of the counterrevolution and before the ultimate defeat of the Ottomans in World War I in Oct. 1918, a reform was established by Young Turks. In this reform, they tried a complete transformation of the Ottoman society. â€Å"While it is difficult to speak of a major policy of Turki-fication in the Ottoman Empire in 1908, the Young Turks certainly envisioned such a policy and tried to implement it increasingly, especially after 1913†. (Sencer , pg 41). According to historians, during this period, CUP initiated many social, political and economic procedures which were followed later in the republican system of Mustafa Kemal Atatà ¼rk. The international position of the empire went worse when Young Turks’ government fell in crisis. Their occupied province of Balkan and Herzegovina was annexed by the Aus-Hungarians. King Ferdinand of Bulgaria also confirmed its independence from the empire. â€Å"The unexpected success of the A. A. Brusilov’s offensive in 1916 be treated as the dying gasp of a ruined army, that the Caucasian Army’s brilliant campaigns against Turkey be regarded as irrelevant sideshows, and so on†. (Showalter, pg 161) Colonel SadÄ ±k and his group of young officers who called themselves â€Å"Savior Officers† combined against the CUP and forced the cabinet to resign. However, the government surrendered before the difficult foreign policy due to which Bulgaria and Serbia made defensive agreements to divide Macedonia. The First Balkan War began with an attack on Montenegro on Oct. 8, 1912 in which the Ottoman government struggled helplessly. By the start of November, Salonika, which was the home and the birth place of the revolution led by Young Turks, was taken by the Greek army. CUP officers under the leadership of Major Enver Bey wrongly believed that the cabinet is discussing options to surrender Edirne. Hence, they shot the Minister of War, Nizam Pasha, and forced Kamil Pasha to resign at gunpoint. Having full control, CUP tried to resolve the crisis and directed the government and the society on the modern transformation path. They took this process even though the war was still going on. They asked Mahmud Åževket PaÅŸa to become the Minister of War. On March 26, 1913 the Bulgarians successfully occupied Edirne and CUP was compelled to surrender the city of Edirne. Mahmud Åževket PaÅŸa was assassinated in Istanbul after a few days. On July 20th, the Ottoman Army, under the leadership of Major Enver Bey, fought back and successfully occupied Edirne and Eastern Thrace. CUP started a steady movement towards the reduction of legal boundaries of the Islamic Shariah. The responsibilities of religious institutions were taken over by three ministries. Shariah courts were handed over to the Ministry of Justice and religious colleges & Madrassahs were given to the Ministry of Education due to which Legal Reforms were codified after fifty years. According to the new family law, the magistrate conducted marriages and the minimum age of brides and grooms was decided as eighteen and twenty respectively. Women took part in nationalist clubs that were opened in Balkans and Anatolia â€Å"In 1908, the Young Turks’ movement faced the basic question: How to preserve, liberate, and consolidate Turkey? The same question stated in a new context had to be faced by Ataturk in 1918†. (Jackh, n.p.) The Balkan War appeared as an idea of a multinational Empire to Young Turks. People of the Empire even Muslims and Albanians preferred the nationalist approach to solve their problems. Non Muslim Businessmen, entrepreneurs and other people having some commercial value in the society had showed sympathy to the objective of the Balkan people. Therefore after 1913 Young Turks regime worked strongly on nationalist economic policy not only to ensure development of genuinely national industry, but also made efforts to freedom from crippling foreign restrictions on Ottoman finances. The Balkan War pushed Turkish nationalism ahead and CUP officially encouraged the association among Balkans, Anatolians and Turkish-speaking people. Besides Turkish nationalism, there were also different ideologies among Turks before World War I started. There were liberal and reactionary Islamic groups that organized on both local and national level. Other than those groups, there were government officials and other intellectuals who supported the westernization of the Ottoman Empire. These ideologies and approaches were not only seen in World War I but it also continued in postwar era. Turkey and World War I On Oct. 29th, 1914 Turkey entered in this great battle when it combined its warships with Germany at Russian Black Sea ports in a mutual naval bombardment. Soon after that on November 2nd, Russia officially declared war on Turkey. France and Great Britain joined hands with Russia against Turkey. The Turks started their attack on the Russian Caucasus area in December and succeeded easily. However, Turkish hold on that area was significantly reduced by the mid of the year 1915. The Turkish hold of the Russian Caucasus area encouraged the Russian government to divert Britain’s attention towards Turkey. â€Å"After the defeat in the World War Turkish nationalism still remained the only option, but the Turkish resistance movement led by Mustafa Kemal Pasha (later Atatà ¼rk) opted for Anatolian Turkish nationalism and rejected irredentist claims. (Karpat , pg 155)† Gen. Sir Ian Hamilton responded the Russian government’s call. In February, 1915 the Allied naval forces of Britain, France and Australia attacked the Turkish forts at Dardanelles but the strong Turkish resistance and the bad leadership of the Allied forces caused complete failure and their troops were called back from Dec. 1915 to Jan. 1916. Meanwhile, the British forces defeated the Turks in many battles in the Indian region during 1914 and 1915 including the major hold on Kut-al-Imara. In the Battle of Ctesiphon, the Turks succeeded in forcing the British forces to retreat from Kut-al-Imara in Iraq. However, In Feb 1917, General Stanley defeated the Turkish forces and captured Baghdad. Planning was started to beat the Turks and the British military operation in Palestine became strong in Middle East during the war. They used Egyptian logistic and strategic bases and supported Arabs to put up a fight against the Turks. General Allenby who commanded Egyptian Expeditionary Force (EEF) started series of war campaigns with the support of Arab Allies in June 1917. Over the period of a year, they successfully destroyed the Turkish frontline. After the surrender, the Turkish government was controlled by the British authorities. The Paris Peace Conference, which was held to impose a resolution, decided to give the Arab and the Balkan provinces under one authority. It was also decided that the areas of predominant Turkish population like southern and eastern Anatolia will be controlled by the foreign forces. Anatolia was invaded by the large Greek army but mass killing of the Turkish population led Allies to stop their support to Greeks. In reaction of the whole situation, the Turkish nationalist movement began for peace settlement in the region. The movement led by Mustafa Kemal Atatà ¼rk   during the Turkish War of Independence from 1918 to 1923 Kemal Atatà ¼rk successfully drove out occupation forces including Greeks, British, Italian and French. With these victories, the Turkish Republic was officially announced in the Year 1923. The First World War had very miserable effects on Turkey. The enforced signing of the Treaty of Serves was meant to divide the Turkish Empire. Turkey was compelled to agree on the terms of the Treaty of Serves. These terms included the French occupation of Syria & Lebanon. Iraq and Palestine came under the hold of England. Egypt was also controlled by the Britons. Saudi Arabia was also declared an independent state. This loss of Arabian Territories by the Ottoman Empire was considered an inevitable fact for them. Though the Treaty of Serves could not be implemented properly because Mustafa Kamal Pasha started the Turk Revolutionary movement also called (Turkish national movement) to regain Asia Minor (Anatolia) and the other city of Constantinople (Istanbul). The Turkish people progressively united under the leadership of Kamal Pasha and terminated the Treaty of Serves. The Treaty of Lausanne was the agreement that repalced the Treaty of Serves. The Turkish Revolution proceeded further to avoided the division of their Empire and to boost their Nationalist Movement. â€Å"The Lausanne Treaty was signed on 24 July 1923 by the British Empire, France, Italy, Japan, Greece, Romania, and the â€Å"Serbo-Croat-Slovene† State on one part and Turkey on the other.† (Lausanne Treaty, n.p.) The aim of the movement was to oppose the partition of the Ottoman Empire after the Armistice of Mudros in 1918 and to end the hostilities between the Allied forces and the Ottoman Empire due to which the Turkish Empire had been divided. The movement was also established to have an independent nation.   Ã‚  Ã‚  Ã‚   The Turk Revolutionary Movement war mainly influenced by the Tanzimat reformation but it was not associated with Young Turk Movement which was established in the same period to keep the Ottoman State bounded togather. â€Å"THE Turkish Revolution began, in the formal sense, with the forcible overthrow of an old political order and the establishment of a new one in 1908.† (Lewis, pg 473) In reality, Turk revolutionaries were not the same kind of people who had similar minds and approaches. They differ with each other in their political and social ideas. They did not even communicate with each other but still they had one common idea which kept them togather which was to have sovereignty. Turks Nationalist Movement under Mustafa Kemal The First World War ended and Ottoman troops were forced to demobilize and disarm except for the purpose of policing. Prisoners of War were freed and military personnel of Austrian-Hungarian and Germany were given two months’ time to leave the Empire. In November 1918, Sultan Mehmed VI, who had succeeded to the throne in July, dissolved the parliament and decided to crush the Young Turks whom he held responsible for the defeat of the Turkish Empire. On 1 January 1919, he opened court martial proceedings against Enver, Talat, and other leading Young Turk officials. He appointed his brother-in-law, Damad Ferid Pasha, Grand Vezir (Grand minister), a position he was to hold for much of the next two years in several different cabinets. He also adopted a stance of cooperation with the conditions of the armistice in order to gain a reasonable peace settlement. The Allies thought that Ottomans must accept dictated peace for there empire. They also had problems on the peace terms associated with Germany. This situation happened because of their conflicting promises to each other regarding postwar distribution of the Ottoman lands. They hoped that United States would take responsibility in the protection and the support of the League of Nations. U.S. President Woodrow Wilson refused to deliver his support to the League of Nations to command over Straits, Istanbul and other six provinces of the empire, where a huge number of Americans were living. On the other hand, most of the Anatolians started to resist against the commanding authorities from the very beginning. They formed an embryonic resistance movement in Anatolia consisting on partisan fighting units and local councils. According to the existing plane laid in Dardanelles campaign earlier, they shipped out their armaments and supplies before leaving the country. CUP founded the National Guards called Karakol before the end of the war, looked after guerilla activities and founded local societies for the defense of rights. In 1934, â€Å"Turks are ordered to take family names. Parliament grants Mustafa Kemal the surname of Ataturk. Women given the right to vote.† (Chronology, pg 341) Karakol helped smuggle Unionist workers out of Istanbul. But that movement was suffering strong leadership. They took an important decision for the Turkish history and group heads of Karakol contacted Mustafa Kemal Pasha known as Atatà ¼rk. Kemal Pasha, who was the founder of Turkish Nationalist Movement, was born in 1881 in Salonika. He graduated in 1904 from the War College in Istanbul. In 1906, Atatruk founded the secret opposition group in Damascus. He took part in Young Turks revolution after his transfer to the Third Army in Macedonia. He was also an active member in the â€Å"Action Army† of Mahmud Åževket Pasha. He participated in the Balkan War in 1911 after which he was posted in Sofia. He was promoted to the rank of Brigadier and Pasha after his courageous efforts in Gallipoli in the First World War. He supervised the Ottoman retreat as a Commander on the Syrian front during the last month of the war. Karakols wanted Kemal Pasha to lead them because they knew his commitment to the CUP and that he had no private connections to the politics of Talat and Enver at the time of the war. The Sultan’s government requested him to go to Anatolia to strengthen the Ottoman troops there. He was titled Inspector of the Third Army and assigned eastern Anatolia with broad authority. In the meanwhile, Entente powers landed the Greek army at Izmir for the enforcement of armistice in Western Anatolia. The Greek forces started their invasion of Western Anatolia. Mustafa Kemal Pasha went to Samsun and immediately contacted the local leaders of the Nationalist Group in Eastern Anatolia through telegraph. He established good relationships with the Commander of the Ninth Army, Kà ¢zim Pasha. With the collaboration of two staff officers Refet Bey and Hà ¼seyin Rauf Bey, Kemal Pasha and Kà ¢zim Pasha prepared a memorandum and distributed it to the Nationalist Group based in Eastern Anatolia. In June 1919, â€Å"Amasya Declaration† denounced the capability of the sultan’s government to defend the area. Therefore, the local people had to defend themselves without any official support. Before the meeting of the National Congress in Erzurum in July, the sultan’s government called back Mustafa Kemal to Istanbul. The sultan relieved Kemal from his command. The National Pact was the first document that came out at the Erzurm congress. This pact was based on six articles. In this document, it was decided that there would be an independent nation with no foreign mandate. It claimed back the former Ottoman territories except where Turks already were in command. Because of the foreign powers, citizens had sacrificed their extraterritorial right and special privileges to minorities were never ensured. The nation would prefer assistance from any power from its own empire. Three weeks later, at the Second National Congress in Sivas, Erzurum declaration was endorsed and expanded due to which the sultan was freed from receiving the blame for the current national crisis and his advisors were blamed for the happening. In Istanbul, there was an ongoing demonstration against the foreign influence and the Greek offensiveness and it had full support of the nationalists. Addresses to the mass rally were getting success in the Turk population. Karakol was sending assistance to the nationalists by recruiting members for the revolution. The city was growing up with thousands of refugees from Balkan and Anatolia. Relief workers got confused when they saw families reunite, arrangements for minor orphans, the returning of demobilized soldiers, and the facilities for the disabled war veterans. The Nationalist Movement won in the elections in the Ottoman parliament which were held after the war. It took majority of the seats. In December, the headquarters of the Nationalist Resistance were moved to the Anatolian town of Ankara. Mustafa Kemal wanted to have a new parliament there but a majority of the deputies wanted to stay in Istanbul and disagreed with Kemal. In Jan.1920, the parliament was opened in Istanbul and by the mid of Feb, the National Pact was adopted. The British Army occupied Istanbul on the 16th of March and arrested several nationalists. Many nationalists hid or made their way back to Anatolia to join the nationalists again. In the elections held for the first postwar Ottoman parliament, sympathizers of the Nationalist Movement won majority of the seats. Among them were Hà ¼seyin Rauf and Dr. Adnan AdÄ ±var. As the parliament prorogued itself in April, the nationalists were denounced as false representatives of the nation by Damad Ferid Pasha. They were even pronounced enemies of the faith and their demise was looked at as a duty of Muslims. A small army emerged to fight the nationalists in April next month. Mustafa Kemal was declared guilty of treason in absentia and was sentenced to death through court martial. Meanwhile, ninety two members fled from the Ottoman parliament to Ankara and thirty two representatives of the Defense of the National Rights along with the members of the parliament constituted the first nationalist parliament also called Grand National Assembly or Great Assembly of the Nation. War of Independence   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   As the government of Sultan Mehmed VI accepted the Treaty of Sà ¨vres on 10th August 1920, the Ottoman Empire was divided and was given under different foreign command. The Treaty was completely unacceptable to the revolutionary nationalists. At the end of September 1920, Turkish nationalists under Kà ¢zim Pasha’s command advanced from Erzurum to SarÄ ±kamÄ ±Ã…Ÿ. The advancement of the Turkish army and Bolshevik’s coup against the Armenian government in Yerevan ended the possibility of an independent Armenia in Eastern Anatolia. The Britons refused to consider any military action against Turk nationalists to impose the peace terms in the region. Italy and France had already started to develop an understanding with the nationalists.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   On the 10th of January 1921, the nationalists defeated the Greeks. Now the international situation slightly shifted in the favor of the nationalists. The Peas Treaty had broken quickly. The Italians and the French concluded arrangements with the nationalists separately to withdraw their influence from Anatolia. These successes brought precious moments for the nationalists. The Turkish people faced a defining moment to their own destiny. The government in Ankara granted extraordinary authority to Mustafa Kemal, who personally commanded the army for three months. A long battle was fought in August and September 1921 on the Sakarya River and Mustafa Kemal & the nationalist forces won the war. After a month, a peace conference was held in Lausanne, Switzerland. Ismet Bey, who led the Turkish delegation, proved his capabilities to be an effective spokesman. A peace treaty was finally concluded in July 1923 known as â€Å"The Treaty of Lausanne† which confirmed the Turkish nationalists’ military victory. â€Å"The state continues to teach that the Republic is based on the secular principles of Atatà ¼rk† (Shank-land, pg 65) the Turkish nationalists got back Eastern Thrace and the whole of Anatolia. The Turkish people finally found their independent country under the leadership of Mustafa Kemal Ataturk. Works Cited Bernard Lewis, The Emergence of Modern Turkey, Oxford University Press, London, 1961. Page Number: 473. David Shank-land – The Alevis in Turkey: The Emergence of a Secular Islamic Tradition, RoutledgeCurzon, New York, 2003. Page Number: 65. Kemal H. Karpat, Studies on Ottoman Social and Political History, Brill, Boston, 2002, Page Number: 840 Robin Higham – Dennis E. Showalter, Researching World War I, Greenwood Press, Westport, CT. 2003. Page Number: 161. Justin McCarthy, The Ottoman Turks: An Introductory History to 1923, Longman, London 1997. Page Number: 349. Emre Sencer, Balkan Nationalisms in the Ottoman Parliament 1909, East Europe, 2004, Page Number: 41+ Chronology, Journal of International Affairs, Columbia, 2000 Page Number: 341. Lausanne Treaty http://www.hri.org/docs/lausanne/ Accessed April 10, 2007 Kemal H. Karpat, Ottoman Past and Today’s Turkey, Brill, Boston, 2002, Page Number: 155. Ernest Jackh. The Rising Crescent: Turkey Yesterday, Today and Tomorrow. Farrar & Rinehart New York, 1944 Page Number: 89.

The Fundamentals of Argue Essay Samples with Issues Revealed

The Fundamentals of Argue Essay Samples with Issues Revealed The upcoming few paragraphs will compose most of your essay. It is essential that the thesis statement ought to be slimmed down so as to adhere to the guidelines of the given writing exercise. A conclusion is, without a doubt, the most significant portion of the argumentative essay because you can either support the fantastic impression or destroy it entirely. Most conclusions are just a paragraph in length as the conclusion is anticipated to be an overview of the whole essay. The Importance of Argue Essay Samples with Issues High school essay examples incorporate a number of short essays like narrative, persuasive and analytical. Writing a high school essay if you've got the tips about how to do essay effectively. An academic essay always must be relevant. 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Personal Account of Being Obese - 1216 Words

When it comes to Obesity i am one of it victims.I have been suffering from it for the past 7 years. Obesity was basically the trigger of all diseases that were in my genetics chain and not to mention the diseases that Obesity forms. In my genetics Blood Pressure,various heart diseases,Diabetes,Bursitis of the knee,Fatigue,Sleep Apnea,Chronic Fatigue syndrome and the one I most hate Insomnia. All of these diseases are present in my genetics some triggered and some on the brink of being triggered to make my life even worse. I have been a victim of Doctors play or basically a Lab rat to be more verbal , many doctors were trying medicines and ways of undefined curing just to make use of what they have and basically get rid of it. Obesity†¦show more content†¦And to end this sub paragraph with an example is similar condition to this addiction is Nicotine addiction where people hallucinate and suffer from migraines to joint pain that is all a signal that the brain does to tell the person to feed the addiction so when he feeds his addiction those pains stop and a good feeling flows through the body thus stating addiction Shifting over to diseases that happen during obesity but for i start did you know that there are 400,000 deaths that were caused by diseases that come from Obesity. Ok now lets start with the diseases that I suffer from, starting with High Blood Pressure or Hypertension well you see this disease is commonly known widely for the elderly but Obesity takes a step forward gives it to ya in any age and the risk to develop such diseases is really high for Obese people than for normal people.You might ask how does it occur well the hearts job is to pump blood through arteries and veins to help organs do their job. You see when a person is obese definitely their is alot of fats in his body so these fats are scattered around the body and the fats that are next to the arteries apply pressure to the blood flow thus making the heart pump out more blood and faster which is known as high blood pressure.Second type 2 Diabetes well I dont really suffer from diabetes but I do have it in my genetics a nd its present in my body but in-order to have it I have to reach level 7.2Show MoreRelatedWhat You Eat Is Your Business894 Words   |  4 Pagesof America. 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