Econometric Studies in Human capital Theory Essay

Econometric Studies in Human capital Theory - Essay Example Furthermore the earnings of certain subgroups who had external structural influence on their schooling were higher than average individuals as a whole. It can be stated that Card focused more on the schooling differences leading to heterogeneous earnings yet revealed some interesting dimensions too (Card, 1830). Much of the literature that examines returns to schooling usually consider academic qualification while in Dearden et al., 2002 she applied econometric model using OLS estimation on returns to academic as well as vocational qualification in Britain. This study is a longitudinal study funded by the then DfEE whereas the sample data of National Child Development Study (NCDS), 1991 and Labour Force Survey (LFS) of 1998 has been used. Her study examines the varying aspects of gender, ability, qualification and family background too. This longitudinal study develops a framework where NCDS results were compare with LFC statistics while after some selection criteria a final sample s ize of 6867 individuals (3007 Male & 3860 Female) was processed through estimation. Estimation results identified that males with O-Levels/ GCSE earn 13 to 23% premium to their qualification while for A-levels they earn 18% and for a degree they yield 11 to 32% premium. In contrast to men, women with O-levels/ GCSE earn 11 to 21% premium and with A-levels it adds to 20% and for degree women return 30% premium to the qualifications in a year. The study confirmed that along with academic qualifications, if individuals acquire vocational qualifications their premium may rise by 40% but vocational qualifications alone have reported less premium (Deardan et... This paper offers review on econometric studies, undertaken with the purpose of determining the correlation between schooling quality and returns on investment on schooling. Over the last decade, many researches and extensive literature have evolved. Card in his study explored the causal relationship of education on earnings. The study explored an impact of an instrumental factor family background on the schooling and earning of their children which had 30% variation in the earnings, similarly college education differences and location near college had some significant influence over schooling and hence earnings. Dearden applied econometric model using OLS estimation on returns to academic as well as vocational qualification in Britain. Results identified that males with O-Levels/ GCSE earn 13 to 23% premium to their qualification while for A-levels they earn 18% and for a degree they yield 11 to 32% premium. In Mcintosh study the variance of qualification confirmed heterogeneous returns among O-levels, A-levels and degree level labour force. The vocational qualification as identified earlier at lower premium to academic qualification remained the same Harmon conducted microeconomic empirical investigation on the returns to schooling. He concluded that every investment reflects the size of returns. He used a comparative approach to analyze cross sectional returns on education and furthermore, he applied OLS estimation analysis. It can be stated that to examine the returns on schooling, an econometric study can best explain the causes of higher returns either that is family background or ability or academic qualification (college graduation, O-levels, university degree) or vocational qualification or training.

Strategic Management of Human Resources Essay Example | Topics and Well Written Essays - 2000 words

Strategic Management of Human Resources - Essay Example ining these ingredients provide the motivation, incentives and sense of purpose, which account for success and also help to explain why some of the familiar mechanistic planning and control techniques work so well in some contexts and not in others (Ahuja, 2005, p.830). The understanding of culture provides better alternatives for decision making by the managers. However, it puts restrictions on the alternatives to the managers, that is, the managers should conform to requirements of cultural patterns of people in the organization. This is so because of two reasons: First, no organization can be isolated from cultural environment, that is, organization as a social unit must operate within the framework of the larger cultural system. As such, a congruency has to be maintained with the values of total culture. Second, organization may be considered as a subculture within the framework of total broader culture. No doubt, every organization develops its own norms and cultural pattern of behavior; these elements are developed within the context of the larger cultural pattern. No part of the system should go against it if both have to succeed. From this point of view, the culture affects the functioning of an organization. Culture places imperative demands on organizations. Culture includes both abstract and material elements. Abstract elements include values, attitudes, ideas, personality types, and summary constructs such as religion, etc. Material elements include all the physical and observable things that man has created and which in turn have an effect on pattern of life and behavior. These elements may be such diverse items as products, buildings, machinery, etc. Though there maybe relationship between abstract and material cultures, both affecting each other, it is much more difficult to change attitudes and value systems than to institute technological innovations. The discrepancy between material inventions and the beliefs and patterning of human behavior

Early reading development

Early reading development The stages of early reading development begin with learning phonemes and graphemes and from this recognition of various words of the English language. The sequence of teaching phonic knowledge and skills should be such that children should have every opportunity to acquire rapidly the necessary phonic knowledge and skills to read independently Rose (2006), Independent review of the teaching of early reading, paragraph 86, page 28. The model below demonstrates the mechanism for early word recognition by using phonic rules of language and the memory of known words. However, as I often observe in class, pupils can read words but are often unaware of their meaning and so cannot fully comprehend or absorb knowledge from a text.(relates to Q10) Children tend to develop comprehension skills by first building an expansive vocabulary of words and their meanings through repeated exposure (visual or auditory) to a wide range of words. By understanding words in context with one another the reader can understand the meaning of the text. Comprehension occurs as the listener builds a mental representation of the information contained within the language that a speaker is usingà ¢Ã¢â€š ¬Ã‚ ¦ the listeners general knowledge and level of cognitive development will have a bearing on the comprehension of the message. To generate an accurate mental representationà ¢Ã¢â€š ¬Ã‚ ¦ the listener has to process the language and the concepts. Rose (2006), Independent review of the teaching of early reading, paragraph 61, page 88 In 1998 the Searchlights Model describing reading was introduced as a way of explaining how a reader processes and comes to comprehend a text. The Searchlights model was incorporated into the National Learning Strategies framework (relates to Q3 and Q15) and designed to provide a simplified way to understand the teaching of reading. It formed the basis for much of the theory of reading which was to follow. Rose (2006), Independent review of the teaching of early reading, paragraph 2, page 73 The model indicates that a text is read by use of four areas of knowledge which act as searchlights to illuminate the text. However, the model indicated that all searchlights were of equal use and deficiency in one area would be compensated for by ability in another. Later findings indicate that both good language understanding and accurate word recognition are required if a reader is to understand the text. Clays model builds on and modifies the Searchlight model by identifying the four cues required for comprehension as phonological (the sound of the oral language), syntactic (sentence order), visual (graphemes, orthography, format and layout) and semantic (text meaning) (Clay, 1985; Clay and Cazden, 1990). Clay highlights that each of these cues are necessary to facilitate reading and understanding of text. Good readers have developed a number of strategies which focus on unlocking meaning of the text whilst poor readers have very few strategies to cope and they tend to have a lack of integration with the text. With the aid of an increasing pool of research into the cognitive processes of reading, the Simple View of Reading indicates the most recent description of understanding of a text. There are two necessary components which must be fulfilled to allow a child to read; Word Recognition (including understanding and pronunciation of words) and Language Comprehension (including understanding sentences and texts) The two elements are interdependent and often facilitate the other e.g. word recognition does not guarantee understanding of those words (ergo nor the text), whilst comprehension is useless without word recognition. Understanding sentences then provides the reader with context to recognise words which follow and subsequently the meaning of the text. The two components of reading have four outcomes in this model by Gough and Tunmer 1986. Rose (2006), Independent review of the teaching of early reading, paragraph 31, page 81 This simple view of reading helps teachers to understand where there students are on the model and what strategies need to be applied to increase their capabilities in either or both areas to help them become good readers. To develop word recognition skills the teaching of phonics is important. Synthetic phonics is taught because our written system is alphabetic, so to be able to read you must first learn the alphabet and the single or combination of letters sounds (spoken letters sound). Children should then learn how to (i) segment words into their component sound to enable spelling and understand the meaning of words and (ii) the complementary process of blending sounds to read words in a process known as synthesis. Success here is clearly impacted by the childs recognition and understanding of the letters of the English alphabet and their corresponding pronunciation as a sound. It is equally important to teach and repeat high frequency words which cannot be sounded-out using phonics; this allows the word to enter the sight memory word bank. To develop language skills, the best ways are through speaking and listening activities, so that students have an opportunity to hear and speak words and understand their meaning in the context of the discussion, increasing their vocabulary and language skills. Considering the above, the Rose review 2006 provides a number of recommendations for best practise in teaching children to read which can be categorised into 5 main area (relates to Q14,15), as follows; Best practiceà ¢Ã¢â€š ¬Ã‚ ¦ The national strategies framework sets out guidance for the development of childrens speaking and listening skills and should be used as a guide for best practice should be expected in the teaching of early reading and synthetic phonics. Quality teaching of phonics would enable the student to develop the ability to decode and encode which is critical to reading and writing/spelling. Phonics work should be cross-curricular using all the strands speaking, listening, reading and writing. Cross curricular phonics teaching also aids students in accumulating a greater stock of words. The teacher must be able to assess progress and react accordingly to maximise the development of each child as an individual with individual needs. The Early Years Foundation Stageà ¢Ã¢â€š ¬Ã‚ ¦. Parents should be encouraged to read with their child before their child enters EYFS. Phonics should be taught from the age of five and should be a multi-sensory approach which captures pupils interests, is delivered in a motivating way by a competent pedagogue capable of reinforcing learning. Greater significance should be placed on word recognition and language comprehension as the key components of learning to read (as a development of the Searchlights model). The EYFS and the National Literacy Framework must work together to create a progressive continuous programme for delivery of phonics which is transportable throughout all years. Intervention if a child struggles to read, including those with SENà ¢Ã¢â€š ¬Ã‚ ¦. If a child is experiencing reading difficulties, it is important to check whether they have a sight or hearing problem which makes learning more complex. Provision of intervention should follow the Primary National Strategy three wave model for students with literacy difficulties. The first wave involves effective inclusion of all students with quality first teaching especially in phonics, wave 2 covers extra intervention to make sure that the student is working at age related expectations with small group intense phonics groups, wave 3 individual interventions make sure that students with extra needs are accommodated e.g. school action and school action plus. It is important to ensure that pupils are not excluded from the main learning goals and progress made during intervention sessions is maintained. Strong leadership and management should be provided in tandem with high staff competency, in terms of subject knowledge and skillsà ¢Ã¢â€š ¬Ã‚ ¦. Head-teachers and staff should make sure that phonics is given a priority within the planning for early teaching to read; staff training should be compatible with this ethos. Staff training must make sure that the phonics programme is delivered to a high standard. To aid this, a head of literacy with specialised knowledge would be beneficial. Passing on knowledge in this way improves phonics teaching overall, is cost effective (due to a dilution of course costs) and allows a specific individual to monitor for consistency of phonics teaching. Those who manage the school should be responsible for instilling an effective continual professional development programme for all staff. With phonics in mind they should oversee the consistency of phonics delivery and provide feedback to improve practice. Management must also monitor pupil progress and instil teaching policy which benefits all pupils by ensuring that they are able to achieve realistic learning goals. Furthermore, Rose suggests that initial teacher training should provide a demonstration of the need to focus on early-years phonics to bring about reading. When observing phonics in my base school I have found that children are grouped by ability for all sessions, with smaller intense groups provided for EAL children. The planning and teaching is undertaken in line with the Letters and Sounds resources in the following way (relates to Q25): First you review and revisit the previous weeks letters and sounds to ensure retention; sometimes the teacher will review the first 100 words using flashcards which the children race to read as many as they can in a minute. Next a new sound is taught, the teacher models how to write the sound and explains the phoneme family (other letter combinations with the same phonetic sound). Practise the new sound by first modelling the writing of a word using the subject sound and then instructing children to write different words which contain that sound. Applying the sound just learned, the teacher writes a sentence (normally something funny) which pupils are asked to read and write their own if time allows. This provides an understanding of the word in context (process two of Simple View of Reading). To bring about word recognition and comprehension the key features of the Simple View of Reading I have observed a number of methods in school; Children are given reading books to take home and practise reading with parents; comprehension and reading accuracy are checked before a child is allowed to change their book. Children are also encouraged to activity use the library facility to take home an extra book they wish to read themselves. This is to encourage them to foster the attitude that being able to read brings many benefits. Daily phonics lessons, taught according to the method described above. Children are given spellings to learn which relate to the phonics they are learning about. Guided reading groups are done regularly to teach the children how to decode and comprehend texts. The children are encouraged to sound out words to find the phonemes when spelling and reading. I have observed many sessions of phonics teaching which have been taught well by effective teachers. This has had a clear benefit to the children being taught and will allow them to become competent readers, an essential skill for success as an adult and fulfilment of the ECM goals which I should strive to satisfy for all pupils in my care. I will draw on the high quality teaching I have observed to provide such quality teaching. The simple view of reading provides a clear framework for success in teaching children to read. Considering Gough and Tunmers (1986) model in relation to a childs ability will allow me to modify my teaching to the needs of each child (relates to Q29). An on-going commitment to understanding research into the best ways for children to learn, and its effect upon best practice, will allow me to deliver teaching which caters for pupils for whom I am responsible. Unfortunately there has not been any indication from the current government regarding their opinion o f and for Literacy teaching. With this in mind, I will carry on with the phonics that I have started to teach. It is clear that I must plan Literacy sessions to include phonics lessons and build on the early learning provided by EYFS teachers. This should be undertaken in collaboration with parents as it is clear that reading from a very early age is most influential upon the childs ability to understand and grasp new knowledge i.e. a successful reader will find future learning easier. My planning and delivery must harness this ethos and the benefits of reading be highlighted to pupils. To allow pupils to gain this benefit, I must create an environment in which I can deliver content in an interesting way which captures the interest of pupils. This environment should also foster a welcoming feedback (relates to Q27) process to allow children to highlight areas where they are struggling and know that help will be provided; learning is best undertaken as a collaborative process by all involved. Bibliography and Reference list Clay, Marie M. (1985). The Early Detection of Reading Difficulties. Third Edition. Portsmouth, NH: Heinemann. (ED 263 529) Clay, M., Cazden, C. (1992). A Vygotskian interpretation of reading recovery. In L.C. Moll (Ed.), Vygotsky and education: Instructional implications and applications of socio-historical psychology (pp. 206-222). New York: Cambridge University Press. Gough, P. B. Tunmer, W. E. (1986). Decoding, reading, and reading disability. Remedial and Special Education, 7, 6-10. Rose, J (2006). Independent Review of the Teaching of Early Reading. Annesley: Department for Education and Skills.

Modern Industrial Economy :: essays research papers

The Modern Industrial Economy   Ã‚  Ã‚  Ã‚  Ã‚  Before the beginning of the eighteenth century, Europe was in dire need of a transformation. One that would change their style of life, not only for the well being of the countries, but for the people as well. This transformation could mean the development of nations into world powers. This need was fulfilled by one word, industrialization. Perhaps the biggest change in history was the Industrial Revolution of the 18th century. This was not only carrying economic changes, but social changes as well. This extensive mechanization from home manufacturing to large-scale factory production was without doubt, the largest conversion for labor fabrication.   Ã‚  Ã‚  Ã‚  Ã‚  Let’s take a look at some necessities for a country to industrialize. First of all, raw materials would be needed in whatever industry you would want to develop. Without a source of power or materials, the product would not be able to be produced at a large factory. Surplus of food is another necessity for industrialization. Without this extensive food supply, laborers would not be fed properly which could result in catastrophic losses. Another major element in the development of industry is entrepreneurs. Since Britain had a sizable middle-class with entrepreneur ideas, they seemed to fit more and more into this equation. Labor Force is also a large contributor to this cause. With an ability of laborers to leave their homes and go into factories, people started realizing the positive effects of big business. One distinct feature that was possessed by Britain was wealth. At the time, Great Britain was one of the wealthiest nations and could afford to dump l arge sums of money into buildings and export. Finally, one of the last things that were needed that could limit all the other elements is the possession of a government that was open to new ideas. If people in a nation could not get their government to back the ideas, they would have nothing. It was up to the entrepreneurs to convince the government officials that money could be made and power could be established.   Ã‚  Ã‚  Ã‚  Ã‚  But why did Britain industrialize first? In the beginning of the 18th century, these qualities were not that noticeable. Actually, the Netherlands and France were just as wealthy at the time, had equally skilled populations, and had just as powerful of an empire. The French government truly was seen as more quick to respond, especially in the area of transportation and communication.

Constitutional Law of the European Union Essay

The European Court of Justice is the driving force behind European integration. The ECJ had elaborately defined the doctrines of supremacy and direct effect of the EC Law and provided remedies for damages caused by breach of EC Law by a Member State . Despite the initiatives of the ECJ, there have been conflicts between Community law and national law. Moreover, the ECJ made it clear that the EC law had supremacy over national law in the event of conflict as evidenced in the case of Costa v ENEL, wherein it held that a preliminary ruling by the Italian courts based on their national law would be of no significance. In Simmenthal, the ECJ clarified that the Community law was to take precedence over national law and that any provision of the national law that contravened the Community Law would be rescinded by it. Moreover, the ECJ prohibited the implementation of any national law that was in conflict with the Community law. The ECJ further ruled that no fundamental provision of any national law could challenge the supremacy of a directly applicable Community rule . This supremacy of Community law is one of the constitutive principles of the integration of the European Community legal order and it has been well embedded in the Treaty that established a Constitution for the European Union. The doctrine of supremacy of Community law, the principles of direct effect and uniform applicability are the primary ingredients of the Community. They are fundamental to the promotion of an effective Community legal order and form the unseen pillars of the European Constitution. Further, the doctrine of supremacy is the actual concrete personification of this constitutional power . The national constitutional courts of Member States found it very difficult to adopt the doctrine of supremacy and in the initial stages the Italian and German constitutional courts almost refused to adopt this doctrine into their respective national legislations, because they felt that they would be surrendering their power of constitutional review of secondary community law. Subsequently, the enlargement of the European Union provided a new paradigm to this doctrine of supremacy. This doctrine of supremacy was enforced by the ECJ in Costa v ENEL . This doctrine is a jurisprudential creation of the ECJ. Further, the Court clarified that the EEC Treaty had adopted a new legal system, which the Member States had integrated into their national legislation. Accordingly, the national courts were required to apply the Community law without any deviation and this generated a number of debates in the Member States. Ultimately, it was accepted by the Member States. However, total supremacy over the national constitutional provisions has not been achieved . In Frontini the Italian Constitutional Court had opined that the 1957 Act, which had accepted the provisions of the EEC Treaty, did not breach the Constitution. Moreover, the Italian court reserved to itself the right to review the continuing compatibility of the Treaty with the Constitution . In another case the Italian Constitutional Court, while accepting the precedence of Community law, maintained that the court had competence over any aspect of the relationship between Community law and municipal law . These decisions clearly established that the national constitutional courts had not completely accepted the supremacy of Community law. The German Constitutional Courts voiced their concern over the protection of fundamental rights in the decisions given in Solange I and II and introduced the concept of Kompetenz – Kompetenze. Even in the Banana case the German constitutional Court declined to give up its power to review secondary community legislation in order to protect fundamental rights . In the United Kingdom this doctrine created several problems, because the UK constitution bestows absolute power on Parliament. Further, the UK ratified a dualist policy concerning the relationship between international treaties and national law. Although such treaties were signed by the UK, they were not incorporated into the domestic law of the UK. In order to incorporate the treaties into national laws, the Parliament had to ratify them and this resulted in a problem in respect of accepting the doctrine of supremacy of Community law over national law. In the famous Factortame case the concept of the supremacy of Community law was subjected to a vast amount of discussion. In that case Spanish fishermen had argued that the norms for registering vessels under the Merchant Shipping Act 1988 were discriminatory and in conflict with the provisions of the EC Treaty. The House of Lords refused to grant any interim injunction against the Crown. The applicants in this case claimed that this would violate the Community law and the result was that a reference was made to the ECJ, which ruled in favour of these applicants. The ECJ further held that any piece of legislation in the national law that prevented a court from issuing interim relief would be tantamount to the violation of the Community law . The EOC case dealt with the suitability of the UK statute regarding unfair dismissal and redundancy pay in the broader context of the EC law . The UK law provided different benefits to employees working in full –time and part – time jobs. The appellant in the case, the Equal Opportunities Commission, opined that the statute was discriminating against female employees, which was in contravention of Article 141 of the EC Treaty and to other Community directives. The House of Lords held that the national legislation had violated the EC law and upheld the contention of the EOC. The approach of the European Court of Justice is at variance with the customary doctrine of precedent that is entrenched in domestic law. The objective of the ECJ is to bring about a European Union that follows the same law throughout its Member States and to this end it constantly endeavours to promote the EC Treaty. This could result in a change in the interpretation of legal principle over a period of time. Moreover, the ECJ bases its decisions on the extant circumstances and not on precedent. National courts of Member States in the European Union can obtain a preliminary ruling regarding the interpretation of European Union Law from the ECJ on the basis of the provisions inherent in Article 234 of the EC Treaty. However, it is not the primary objective of the ECJ to take decisions regarding the compatibility between the domestic and European laws. Further, it is also not the primary aim of the ECJ to apply the European Union Law to some specific facts of a case . The ECJ indicates the principle to be applied in a particular case and the case will have to be decided in the originating court, however, the ECJ ruling will have to be implemented by such a court. In the absence of an appeal from a national court, a reference will have to be made by the originating court, in case it is of the opinion that a clarification in respect of European Union Law is required. Nevertheless, there are instances where an ET, EAT or Appellate Court has to make a reference to the ECJ in order to pronounce judgement that is in accordance with the EU law. The function of the advocates general is to aid the judges in their judicial work. They do this by submitting analyses and recommendations regarding the issues raised in a particular case . In addition to the rights conferred on the nationals of the EU Member States by their respective national constitutions, the EU law comprises of another source that grants rights to them. As such the European Union law constitutes a legal system that in addition to being independent also, perhaps more importantly, takes precedence over the national laws of the Member States of the European Union. This European Union law comprises of treaties, which constitute primary legislation and regulations and directives that constitute secondary legislation. The importance of regulations is that they directly require compliance from the Member States without having to be codified into the national laws. However, in respect of the Directives, which are also legally binding, the onus of implementing them rests squarely with the Member States and these Member States have to do so by resorting to the relevant national law legislation on or before the final date set by the EU for such implementation. Accordingly, Article 189 of the European Economic Treaty states that â€Å"A Directive shall be binding, as to the result to be achieved, upon each Member State to which it is addressed, but shall leave to the national authorities the choice of form and methods. † The European Court of Justice, subsequent to taking cognizance of the fact that Directives have to be implemented by the Member States, declared that individuals were well within their rights to ensure the implementation of Directives even in the event of failure by the Member States to meet the deadline set by the EU. In addition, individuals were permitted to enforce such rights in the national courts. The Van Gend en Loos decision unequivocally established the fact that in addition to creating obligations for the Member States to implement the Directives it also creates rights for the individual citizens of these Member States . The right of the Member States and the European Commission to proceed against other Member States before the European Court of Justice does not prohibit the lodging of complaints by individuals against the Member State to which they belong in their national courts. In this context, the European Court of Justice ruled that Article 12 of the EEC results in direct effect, which in turn result in the creation of rights for individuals and that these rights had to perforce protected by the national courts. Consequently, individuals have been empowered to ensure that rights granted by the Directives are enforced in the national courts . The offshoot of this is that individuals can ensure the implementation of human rights by resorting to legal action. In the Becker case it was clarified that if there is unconditionality and adequate precision in the provisions of a Directive that bestows individual rights, then individuals can resort to such provisions to contest the relevant national law . Furthermore, in the Francovich case the European Court of Justice established a test in three parts, which was to be utilized in order to ascertain whether the provisions that were inherent in a Directive, were sufficiently precise and unconditional in creating a right that was applicable to individuals. The ECJ has to consider the identity of the persons who are supported by the guarantee and the content of the guarantee. The identity of the person in breach and who is liable to pay the guarantee has also to be ascertained. Private persons and institutes cannot be subjected to the provisions of the Directives, because it is only the state that is subject to the Directives. The decision in the case of Francovich served to establish that damages could be claimed by an individual in a national court, in the event of a Member State’s failure to implement a Directive properly. The ECJ clarified that the spirit of the European law and the protection of rights would become ineffective if an individual failed to secure compensation. Moreover, the States are required to implement Directives wholly and properly. The ECJ decided in Brasserie du Pecheur v. Germany that there must be a sufficiently serious breach by the State in order to determine its liability. This dictum applies to situations where national legislation is implemented improperly and inconsistently with a Directive. In order to determine whether Community law was breached with sufficient seriousness, it is sufficient to demonstrate that the Member State or Community institution had seriously and knowingly ignored the limits to its discretionary power. Some of the factors that the court has to consider are the exactitude and clarity of the rule that was breached, the amount of discretion allowed to the national or Community authorities, whether the damage caused was intentional or not and whether there had been any adoption or rejection of measures that were in violation of the Community law . Member States for whom the Directives are specifically issued should be bound by them. Sometimes Directives can be addressed to one Member State or a group of them, but in general Directives are addressed to all the Member States. The exception to this practice is in respect of Directives that pertain to Common Agricultural Policy. The European Commission initiates a binding legal action in situations where a Member State fails to incorporate the provisions of a Directive into their national legislation or if the national legislation fails to properly fulfill the requirements of the Directive. Previously, the Directives were not adequately binding upon the Member States in their implementation. To address this problem, the ECJ promoted the doctrine of direct effect. Thus even if a Member States fails implement the Directives there is legal initiation under the principle of direct effect. This was clearly established in the case of Francovich v Italy. In that case, the ECJ attributed liability to Italy for its failure to implement a Directive. The Easytalk was a private limited company that had been formed with help from the UK government. It was established in order to encourage students in the EU to come to the UK in order to learn English. This company advertised all over the EU universities by means of pamphlets, in which it was stated that the course instructors would be highly qualified scholars in English with a great deal of teaching experience. A Directive was issued by the EU that prohibited the issuance of advertisements that misled and imparted false information. This Directive was to be implemented by January 2007. However, the UK government failed to implement this Directive by this deadline and in effect this Directive had been ignored by the UK government, because the latter was of the opinion that this Directive was unlawful. Subsequently, a French student, Antoine came to the UK and registered for a course that taught English. However, once the classes commenced, Antoine realized that the faculty comprised of students who were not qualified teachers of English as a foreign language. On being approached, the institute where he had enrolled refused to refund the fees paid by him. The direct effect of directives has been restrained by the concepts of vertical and horizontal effect. Van Duyn and Ratti affirmed that directives only have vertical effect so that an individual who is affected by the states’ failure to implement a directive properly or not at all only has rights against the state and not against a non-state entity or other individuals, as the directive imposes the obligation of implementation upon the state. Therefore a horizontal limitation was placed upon the scope of the direct effect of directives. This principle was addressed in Marshall v Southampton and South West Hampshire Health Authority , in which the applicant who was employed by the Health authority, was required to retire at the age of sixty – two years, while men doing the same work did not have to retire until the age of sixty – five years. Although under national law, by virtue of the Sex Discrimination Act, this was not discriminatory, she succeeded in her claim for unfair dismissal by relying on the Equal Treatment directive, which had not been implemented in the UK. This directive was sufficiently clear to have direct effect but the courts took the opportunity to confirm that a directive may not of itself impose obligations on an individual and that a provision may not be relied upon as such against such a person. Therefore since the health authority was an organ of the state, the directive had vertical direct effect. Since the respondent in this problem is a private limited company, the claimant cannot approach the Commission under the vertical direct effect. However, he can seek justice under the EU law by resorting to the procedure of indirect effect. Since, the UK government had not implemented the Directive; the claimant can approach the national courts of the UK to compel the government to apply the Directive. In respect of damages, the ECJ further held in R v H. M. Treasury, ex parte British Telecommunications plc that parties who had sustained loss as a result of incorrect implementation of a directive by a state, could claim damages for the loss sustained on such an account. In contrast to this, if a state has failed to fulfill its obligations regarding Directives, whether by non-implementation or incorrect implementation, an individual cannot request invocation of the horizontal direct effect of a directive against another individual. Similarly the effectiveness of non-implemented or incorrectly-implemented directives that do not have direct effect through the horizontal limitation has been enhanced through the doctrine of indirect effect, which emerged from Von Colson . In this case the ECJ held that national courts are required to interpret their national law in light of the wording and the purpose of the directive so that the directive is given some effect despite the absence of proper domestic implementation. This principle may be used under two circumstances; first, where the defendant is a state entity but a directive is not vertically directly effective as its provisions are insufficiently precise, conditional and require further state action for their implementation. Second, the provisions of a directive could be indirectly enforced against a non-state entity i. e. it could be applied horizontally as between individuals. The court was confronted with a ‘horizontal’ situation in Marleasing , in which this position was confirmed. Therefore, if national law was in existence that could be read in conformity with a non-implemented directive, then an individual could enforce a legal remedy against another individual through the interpretative route without seeking to enforce the directive directly and encountering the barrier to horizontal effect. In respect of the Easytalk institute the claimant can file a case for breach of contract and false representation in the UK courts in order to obtain redressal for the loss, damage and frustration caused to him. The question arises as to whether the aggrieved individuals can claim damages against the state in the national courts. The ECJ clarified that the state had to pay compensation for the damages caused due to non – implementation of a Directive and that the conditions laid down for such claim of damages must not be less reasonable than what was specified for a domestic claim. Furthermore, the Member State should not unduly complicate the claim process.

Succubus Revealed Chapter 14

Seth shot up from the chair, face filled with hurt and fury. It was surreal. For a moment, he looked like a stranger . . . and yet, he also looked like everyone I'd ever known. Everyone I'd loved. Everyone I'd hurt. â€Å"You,† he exclaimed, striding toward me. â€Å"How could you do that to me? How could you do that to me?† I had never heard Seth yell like that. I cringed against my chair, too stunned to react. Meanwhile, Hugh seemed to come to life. He had been as shocked by Seth's initial reaction as me, particularly since Hugh understood even less than I did about what was going on. He was still undoubtedly confused, but some instinct spurred him to action when he saw Seth advance. I didn't think Seth would've hurt me, but he was kind of scary just then. Hugh grabbed a hold of Seth's arm. â€Å"Whoa, whoa,† said Hugh. â€Å"Easy there. Everyone calm down.† Roman likewise seemed to suddenly realize something was wrong here. He'd been so excited by the developments, his face aglow as all his theories fell into place. Now events were moving in a direction he hadn't foreseen. He rose, mirroring Hugh's fighter's stance. Only, Roman was doing it defensively, coming to stand in front of me, in case Seth broke Hugh's hold. That didn't seem very likely. The imp was strong. â€Å"How could you do that to me?† repeated Seth, voice still roaring with fury. â€Å"I trusted you! I trusted you and I loved you!† I had witnessed all of this unfolding but hadn't dared allow myself to really and truly accept it. I had seen the impossible. I had seen Seth relive the lives of men he hadn't known – men he couldn't have known – walking back through the centuries of my long existence. Some voice inside of me kept saying, No, no, this isn't happening. This can't be real. It's some trick of Hell's. I was working hard not to process what I'd heard because processing it meant accepting it. But with those last words, Seth penetrated something inside of my numb self. He broke through, and I snapped. â€Å"I didn't! I didn't do anything to you!† I cried. I had to peer around Roman to meet Seth's eyes and almost wished I hadn't. They were cold. So terribly cold and hurt. â€Å"You cheated on me,† said Seth, straining against Hugh. â€Å"Cheated on me with my best friend. . . .† Yet, even as he spoke, I could see him falter. The feelings he'd felt as Kyriakos were real, but he was examining it now as Seth Mortensen. The mixed realities were confusing him. It was understandable. They confused me. â€Å"Seth,† I said desperately. â€Å"I didn't do that to you. Think about it. I love you. I love you so much.† Seth stopped struggling, though Hugh didn't relinquish his grip. Seth's features were still filled with hurt and confusion. â€Å"Not to me . . . to him. But I am him. I'm all of them.† Seth closed his eyes and took a deep breath. What had been reasonable and clear under hypnosis was becoming more difficult to grasp. â€Å"How? How is that possible?† â€Å"Past lives,† said Roman. â€Å"You're right. You were all of them. You lived all of those lives, long before you were born into this one.† â€Å"Reincarnation? That . . . that's impossible,† said Seth. â€Å"Is it?† asked Roman, regaining some of his confidence now that the situation was no longer escalating. â€Å"How do you know? Do you have a direct line into the way the universe works?† â€Å"So, wait . . . what about you guys?† asked Seth. â€Å"Are Heaven and Hell not real?† â€Å"Oh,† said Hugh wryly, â€Å"they're real.† â€Å"All of it is real,† said Roman. â€Å"And vastly more complex than any faulty human system can understand.† He turned to me, expression softening. I must have looked terrified. â€Å"What Seth saw . . . what he lived through. You knew all of them, didn't you? All of those identities?† I focused on Roman, afraid I'd lose my nerve if I looked at Seth again. I nodded. â€Å"Yes . . . they were all people . . . all men I knew in my life.† Hugh frowned. â€Å"How is that possible? I can get on board with reincarnation. I've seen enough to believe it can happen. But him always being reborn around you? You running into him – what was it, ten times? That's statistically impossible.† â€Å"The things we're dealing with aren't really governed by statistics and probability,† said Roman. â€Å"There are other forces at work here, forces that guide his rebirth. It was part of his contract, the deal you made as Kyriakos. What can you tell us about it?† â€Å"I don't know what you're talking about. . . . I don't remember . . . I . . .† Seth shook his head, the anger returning. â€Å"I don't want to talk about this anymore. Let me go. I need to get out of here. I need to get away from her!† â€Å"Seth . . .† I said. â€Å"But you're the key!† exclaimed Roman. â€Å"The key to unlocking Georgina's problems. You're the other contract, the one Erik was talking about. You're tied to her, tied to everything that's been going on with her.† â€Å"I don't care,† said Seth. He seemed to just barely be able to keep his emotions in check. â€Å"I don't care about your various and sundry plots! Do you have any idea what I just saw? What I just went through? I'm still not even sure I understand any of it! I don't understand who I am! All I know is her – and what she did to me.† â€Å"Seth,† I tried again. Or should I address him as Kyriakos? I didn't know. â€Å"Please . . . I love you. I've always loved you. What happened . . . it was . . . it was an accident. . . .† The look Seth gave me was dark and wary. â€Å"It sure didn't seem like an accident when I walked in on you.† â€Å"I never meant to . . .† â€Å"To rip my heart out?† he cried. â€Å"To destroy my world? My life?† â€Å"Roman,† said Hugh carefully. â€Å"Maybe we should give him some time to process this.† â€Å"We don't have time,† said Roman. â€Å"Hell can move fast – especially if they find out what we know. If we're going to save Georgina – â€Å" â€Å"I don't care!† said Seth again, this time with more vehemence. â€Å"I don't care what happens to any of you, and I certainly don't care about what happens to her. It's probably less than she deserves.† â€Å"She didn't do anything to you,† said Roman. â€Å"She's been a pretty solid girlfriend, from what I've seen.† â€Å"Seth,† I pleaded, knowing Roman wasn't quite getting it yet. â€Å"I . . . I'm sorry. It was a long time ago.† My words were terribly, terribly inadequate, but Seth was tapping into things I'd forced myself to block out – because they were too painful. â€Å"For you, maybe,† said Seth. â€Å"It happened over the course of centuries. One life for you. But for me . . . whatever you guys did with the hypnosis, it's all here now. All of those lives . . . those memories. Here in my head at the same time. It didn't happen ‘a long time ago' for me. It's like it just happened yesterday! All those feelings, all that pain . . .† â€Å"It'll fade,† said Hugh, not sounding as though he was certain. â€Å"What you regressed through is still fresh, and you weren't brought out of the trance properly. Give it time. Or . . . if you want, I can put you back under and make you forget this.† â€Å"And forget her?† demanded Seth. â€Å"So I can forget what a faithless, conniving bitch she's been to me?† â€Å"Seth . . .† I could feel tears forming in my eyes. â€Å"I'm sorry. I'm so sorry. If I could take it back, I would.† â€Å"Which part?† he asked. â€Å"The part where you proved our marriage meant nothing to you? Or the countless other times you lied to me and broke my heart? Do you have any idea how I feel? What it feels like to be experiencing all of that at the same time? Maybe you've moved past it all and don't care anymore, but it's real for me!† â€Å"It is for me too. I . . . I love you.† They were the only words I managed to get out, and they still weren't enough. Where was all my usual glib charm? My ability to talk my way out of anything? I was still too choked up on my emotions, still reeling from the fact that looking into Seth's eyes meant looking into the eyes of every man I'd ever loved. I wanted to convince him how sorry I was and explain that having a long life hadn't dulled the feelings inside me. If anything, it had only provided more time for those feelings to sink in and punish me. I wanted to explain to him how I'd felt during that first transgression and how it had been a poor reaction to feelings I didn't know how to process as a scared young woman. I wanted to explain that most of my actions since then, especially the times I'd pushed away other lovers, had been weak attempts at protecting them. There was so much I wanted to say, but I just didn't have the words – or courage – to get any of it out. So, I remained silent, and the tears spilled out of my eyes. Seth took a deep breath, forcing. â€Å"Let me go, Hugh. I won't hurt her. I don't want anything to do with her. I just want to go home. I need to get out of here.† â€Å"Don't,† said Roman. â€Å"We need him. We need more answers, so that we can understand the contracts.† â€Å"Hugh, let him go.† I barely recognized the voice as my own. Roman looked at me incredulously. â€Å"We need him,† he repeated. â€Å"He's done enough,† I said flatly. In my head, Seth's words echoed: I don't want anything to do with her. â€Å"We've done enough to him.† When nobody reacted, I met Hugh's gaze squarely. â€Å"Do it. Let him go.† Hugh glanced between Roman and me and then made a decision. Still keeping hold of Seth's arm, Hugh steered him away from us and walked him to the door. Roman made more protests and took a few steps toward them, but I remained frozen where I was. I didn't look behind me, not even when I heard the door slam. Hugh returned, and Roman slumped back into his chair, sighing with frustration. â€Å"Well,† he said. â€Å"Once he calms down, we'll get him back and talk things out.† â€Å"I don't think he's going to calm down,† I said, staring off at nothing. I don't want anything to do with her. â€Å"He's just in shock,† said Roman. I didn't answer. Roman didn't know. Roman didn't understand the full scope of our history together. He hadn't seen Kyriakos's face after my betrayal, the grief that had been so deep it had nearly driven him to suicide. That was part of why I'd become a succubus, using my soul to purchase peace for him in the form of forgetfulness. It was the only way to save him. But if he remembered everything now, if he really was Kyriakos reborn . . . then, no. He wasn't â€Å"just in shock.† I had done a terrible, terrible thing to him, and his outrage wasn't unfounded. A shiver ran through me as I thought about the instant connection I'd had with Seth, the feeling like I'd always known him. It was because I had always known him. Life after life. I'd always felt like we were bound into something greater than ourselves . . . and we were. Something great and terrible. Hugh dragged up a chair and sat across from me. He caught hold of one of my hands. â€Å"Sweetie, I swear to you, I had no clue any of that would happen.† I gave him a halfhearted squeeze back. â€Å"What . . . what did you think would happen?† Hugh glanced at Roman. â€Å"He asked me if I could hypnotize Seth and attempt some past life regression. I had no idea what it was for. Fuck, I had no idea it would really work, let alone walk us through nine emotionally damaged lives. Ten, since we now seemed to have fucked up this one.† I felt hollow inside, hollow and aching. I turned to Roman, astonished I could manage any sort of reasonable discussion when my world had just been destroyed. â€Å"How did you know it would happen? How did you figure all of this out?† â€Å"I only figured some of it out,† said Roman. â€Å"It was actually your stupid Santa stuff that tipped me off. About how that guy was worried about Santa being in two places at once?† He scoffed and raked a hand through his hair. â€Å"I started thinking about how everyone says your contract is fine and how Erik had mentioned a second contract. We'd already deduced Hell wanted you and Seth apart, but why? And I thought, what if it's like the Santa thing? There's nothing wrong with your contract or Seth's in and of themselves, but together, something goes wrong.† â€Å"How did you even know Seth had a contract?† asked Hugh. â€Å"Well, that's the thing. I didn't. And since Seth had never mentioned it before, it seemed he didn't know he had one either. And how could that be? I started thinking maybe it was because he hadn't made the contract in this life. I thought maybe Hell had a long game going on with him across lives, and hence . . . the hypnosis.† â€Å"Jesus Christ,† said Hugh, shaking his head. â€Å"You made a fuckload of deductions there.† â€Å"And they were right,† said Roman. â€Å"Georgina and Seth both have contracts with Hell. And those contracts don't work together.† â€Å"Why not?† I asked. That zealous gleam was back in Roman's eye. â€Å"What were we able to deduce about Seth's contract? What did he get?† The only thing I'd deduced was that Seth was never going to speak to me again. When I refused to answer, Hugh obligingly played student to Roman's teacher. â€Å"He got ten lives instead of one. The gift of reincarnation.† â€Å"Why?† asked Roman. â€Å"To find Georgina,† said Hugh. He paused, and I guessed he was replaying what Seth had described. â€Å"It sounds like he died in that first life, and when the time came for his soul to move on, he was aware of missing her. I'm guessing Hell wouldn't have gotten his soul then, so they made the deal to give him nine more chances to find Georgina and be reunited with her.† â€Å"He did find me,† I said flatly. â€Å"Over and over.† Betrayal after betrayal. â€Å"Yes,† said Roman. â€Å"And you were drawn to him without even realizing it. He certainly seemed to fit your dreamy artistic type each time. But you never made it work out.† â€Å"Which Hell was probably hoping for,† said Hugh. The imp in him was coming out, puzzling over how a contract like this would have been designed. â€Å"Hell has to be fair, but they always want an advantage. So, they probably went into the deal thinking a guy hoping to make amends with his soul mate could never do it if she was a succubus. Seth – or whoever – certainly didn't know that. He only knew that he was supposed to have forgotten her.† He thought about it a few moments more. â€Å"There's nothing wrong with that, though. That's hedging your bets on a contract. There's no violation.† â€Å"You're right,† said Roman. â€Å"And that's not the problem.† He focused back on me. â€Å"What was your deal? What was your contract for becoming a succubus?† â€Å"You already know it,† I said wearily. I was tired of the scheming and fallout. I want to crawl off, curl up in my bed, and sleep for the next five centuries. I wanted to renegotiate my contract and have my memory and heart purged of all pain. â€Å"Humor me,† he said. â€Å"Just tell me the basics again. The deal Niphon made with you.† â€Å"Roman, leave her alone,† said Hugh. I waved him off. â€Å"Fine. I sold my soul and became a succubus in exchange for everyone I knew as a mortal forgetting about me.† Roman looked so supremely satisfied and triumphant that I wanted to punch him just then. He nodded to Hugh. â€Å"And tell me Seth's again, to the best of your guessing.† â€Å"At a guess? He gets to live ten lives, all of which will put him near her, giving him the chance to find her and make amends with her. Hell gets his soul at the end of the tenth life.† â€Å"And why did Seth make the deal?† prompted Roman, practically trembling with excitement. â€Å"Because he remembered that – † Hugh cut himself off, eyes widening. â€Å"Exactly,† said Roman. He shook me in his excitement when I didn't react right away. â€Å"Don't you get it? Your contracts contradict each other! In fact, Seth's should never have even been written! He remembered you. He knew that you were gone from his life.† â€Å"He knew his ‘soul mate' was gone,† I said bitterly. â€Å"I don't think he remembered specifics. You saw how much trouble he had.† Roman shook his head. â€Å"Doesn't matter. I'm guessing your contract specifies forgetting you entirely. He remembered. By that happening, Hell violated your contract. Then, they wrote an impossible contract for him, claiming he'd have the chance to reunite with you – which again, implies a degree of remembering you.† â€Å"We don't know that exactly,† warned Hugh. â€Å"We haven't seen the contract and didn't get all the details from him. I couldn't follow if he got anything for patching things up with her or not.† â€Å"We know enough,† said Roman. â€Å"Seth wanted to be reunited with her and make amends. For that to happen, it would contradict Georgina's contract – specifying he forget her.† â€Å"I'd want to see the wording,† said Hugh. â€Å"I'm not trying to dash your hopes. I just know how these things work.† â€Å"Fair enough,† said Roman. â€Å"But can you deny that when Seth called her ‘Letha' last month, that was most definitely in violation of her contract? He remembered. Not consciously. But some part of him, deep inside, remembered her.† My thoughts were still moving sluggishly, but something clicked into place. â€Å"The transfer . . . the transfer came through the morning after I told Jerome about Seth calling me Letha.† â€Å"Yes,† said Roman. â€Å"That's why things were mucked up with it. I guarantee my dear father has always known about your contracts and has accepted them grudgingly, especially if Seth's contract allows for you two to keep running into each other. But, when you told the gang about the name, Jerome had a serious problem. He recognized the violation and tattled to his superiors as fast as he could, making them panic and act quickly – too quickly – to get you out of here.† â€Å"But . . . it already happened. Seth remembered. The violation took place,† I said, scarcely able to believe it. â€Å"It's like a tree in the woods,† remarked Hugh. â€Å"It only happens if they're called on it. Neither you nor Seth would have known about the contracts or any violation. You were oblivious. Jerome needed to keep it that way, get you guys apart and kill any chance of you figuring out what had happened.† â€Å"Hence the Vegas dream job,† said Roman. â€Å"It's like we talked about before. Forbidding you guys to be together would've drawn too much attention. A run-of-the-mill transfer, however, would've seemed like business as usual – if not for the screwup. Hell was so anxious to get it going that they sent you the memo before Jerome had a chance to meet with you. I guarantee everything you saw in Vegas was thrown together on a day's notice.† I drew my hand back from Hugh's and buried my face in my palm. â€Å"Oh God.† Roman patted my shoulder in a way that was probably supposed to be comforting but mostly made me grit my teeth. â€Å"God's not the one you've got to look to right now. Do you realize what you've got here, Georgina? A once in a millennium opportunity to thwart Hell! You can challenge them, call your contract into dispute. And Seth's. All you need to do is talk to him, get the exact details of – â€Å" I jumped up from my chair, finally giving way to all my own grief and fury. â€Å"No! Didn't you see his face? Didn't you hear him? He won't talk to me! Not now, not ever. And don't say he's just in shock again,† I warned, seeing Roman about to speak. â€Å"You don't know what I did, what it was like for him . . . back then. There's a reason I made him forget! He's not going to forgive me for this. Never. He didn't then and isn't going to now. Oh Lord. Why did we have to do this? Why did we have to make him remember? We should've just let him forget. . . . Everything was fine. . . .† My frantic pacing led me over to the living room window, where I drew back the curtains. It was late in the day now, the sunset turning the clouds orange. â€Å"Fine?† asked Roman, coming to stand beside me. â€Å"Hell was creating elaborate ploys to separate you and cover their asses! And they were killing his sister-in-law to do it. That is not fine. You and Seth have done nothing but play into Hell's hands all these centuries. Over and over, you find each other and lose each other, you bicker and fight, throw it all away on mistrust and lack of communication. Are you going to let that continue? Especially when they didn't even give you what you were promised?† I rested my cheek against the glass, taking comfort in the coolness, refusing to listen to Roman's logic. â€Å"But Seth didn't remember until we made him.† â€Å"Not true. He remembered before that,† said Roman. â€Å"On his own, when he called you Letha. That's how this all started. Nothing we did here changed that.† â€Å"He hates me,† I said, fully aware of how whiny I sounded. Roman didn't try to deny it. â€Å"People forgive.† I scoffed. â€Å"Do they?† â€Å"They do,† said Hugh, coming to stand on my other side. â€Å"Seth must have – or whomever he used to be. Your husband. Why else would he have made that bargain in the first place to find you?† â€Å"Because he didn't remember what I'd done,† I said. I met Hugh's eyes. â€Å"He only knew that I was missing from his life.† â€Å"You answered your own question, sweetie. His love for you was stronger than his hate, if he was able to remember the one and not the other.† I wanted to argue with that but didn't know how. â€Å"I can't . . . I can't face him. You don't know what this is like. It's . . .† My lifelong fear? My greatest sin? â€Å"I just can't.† â€Å"We need to know about the rest of his contract,† said Roman. â€Å"We need all the details if we're going to see this through.† Hugh sniffed. â€Å"You keep saying ‘we,' but somehow I don't see you being the one filing the paperwork with Hell to challenge her contract.† When Roman didn't answer, Hugh added, â€Å"Which, by my estimate, we don't need any more of Seth's information for. We already have enough to question her contract's integrity.† â€Å"Question its integrity?† exclaimed Roman. â€Å"We have enough evidence to blow it wide open.† There was that metaphor again. Roman loved the dramatic. â€Å"Hell failed to hold up their end of the bargain. They told you they'd make everyone forget. Obviously, they didn't.† â€Å"It may not be quite that simple. Hell will question what you call evidence,† said Hugh. â€Å"But it can be done, right?† asked Roman. â€Å"You know how to do it – to file the necessary paperwork?† â€Å"Well, I've never done it before,† said Hugh. â€Å"Jesus. I don't know anyone who's done it.† I dragged my gaze from the window. â€Å"Don't,† I told Hugh. â€Å"It's not worth it. You don't know anyone who's done it because no imp who values his job or his life would ever try to get a contract revoked. I don't want you doing that for me.† â€Å"Hugh,† said Roman, looking over me like I wasn't even there. â€Å"You could free her. You could get her soul back for her. You could end this life she has – sleeping with strangers for eternity.† â€Å"Stop it,† I snapped. â€Å"Stop trying to guilt him into it. I made this choice. No one tricked me into being a succubus. They told me what it entailed and what I'd get.† â€Å"And you didn't get it,† said Hugh quietly. â€Å"It doesn't matter,† I said. If I didn't have Seth, one form of Hell was as bad as another. â€Å"I would do it for you,† said Hugh. â€Å"I'll file the paperwork. Maybe you knew what you were getting into, but that doesn't mean you don't have the right to change your mind – especially if you were played. If you want it, I'll help you do it.† â€Å"Why?† I asked, recalling all the times Hugh had become uneasy whenever we'd talked of challenging the status quo. â€Å"Why would you risk it?† â€Å"Because you're my friend,† Hugh said, his lips twisting into a bitter half smile. â€Å"And that still means something to me. Besides, give your pal Hugh some credit here. I might be able to pull this off with minimal punishment for myself.† A strange feeling welled within my chest, tight at first and then loosening. This day had become one impossible thing after another. Somehow, hearing Hugh say it made it more real. I was so used to Roman's ideas and dreams for undermining Hell that at times, it was easy to ignore them. But to hear Hugh saying this might actually work . . . I swallowed, feeling more tears were on the way. â€Å"I can't even imagine that. A world where I don't belong to Hell. I don't know what my life would look like.† â€Å"Like anything you want it to,† said Hugh, wrapping me in a hug. Behind me, I heard Roman sigh. â€Å"Well. I'll settle for one contract blowing up in Hell's face. I mean, Seth was already Hell-bound anyways, wasn't he? With or without any of this?† I winced. It was true. Seth's soul – once so bright and shining – had darkened when he cheated on Maddie with me. He'd come to my bed out of love but had still felt guilty over what he'd done. The mark of sin had tainted his soul enough that were he to die right now, Seth would go to Hell. Hugh cleared his throat and let go of me, suddenly looking uncomfortable. â€Å"It's funny you mention that. . . .† â€Å"Why?† I asked. â€Å"I hadn't seen him in a while and nearly didn't notice . . . but today when he was here, his soul . . .† Hugh shook his head. â€Å"I don't know what all he's done, but it's lightened. It's not the spotlight it used to be, but something's changed. Enough of the taint's gone now that I don't think he's marked for Hell anymore.† â€Å"Except, he is because of his contract,† I realized. â€Å"That was the price for all those lives. It doesn't matter how good he is.† I felt my legs grow weak again and had to struggle to stay up. Seth had redeemed himself for his sin. How? Probably through the sacrifices he'd made for his family. He'd given up the things he loved most for them – writing, even me. It was a remarkable feat, something few humans were able to rebound from. Usually, those who were damned stayed damned. But it didn't matter. Seth's soul could shine like a supernova and he would still go to Hell, because it was the same soul he'd had as Kyriakos, the one that had made the bargain to come and find me. â€Å"We don't know for sure,† I said. â€Å"He didn't make it clear if he definitely signed his soul over or if there was a wager, like he'd get to keep it if he made amends with me.† â€Å"Which doesn't really seem like it's going to happen at the moment,† said Roman. â€Å"So either way, he's damned.† â€Å"Unless we can break his contract too,† I said. â€Å"And we need his help for it.† Hugh gave me a sympathetic look. â€Å"Do you want me to try to talk to him?† I had hated myself for what I'd done to Kyriakos all those years ago, hated myself so much that I'd paid the ultimate price to be wiped from his memory. And after seeing the look in Seth's eyes earlier . . . well, honestly, if given the chance, I might very well have asked to be erased again. I couldn't stand seeing that hate, that disappointment in the eyes of someone I'd loved. I'd hurt him. I'd let him down. I wanted to hide and never see him again because if I faced him, I would have to face the failings within myself. That had always been a problem for me, I realized. I hated confrontation – especially when I was the one at fault. I'd continually run away from that my entire life. I forced a weak smile for Hugh, who stood there offering me a cowardly way out. No, I decided. If we were going to get Seth's help, it would be better coming from me. Would he talk to me? I didn't know, but I had to try. For nothing else would I have risked facing that hate and sorrow again . . . but for Seth's soul, I would. â€Å"I'll go to him,† I said.