Wednesday, December 25, 2019

Payments in Construction Law - Free Essay Example

Sample details Pages: 4 Words: 1115 Downloads: 10 Date added: 2017/06/26 Category Law Essay Type Case study Did you like this example? INTRODUCTION In construction environment, payments was defined as the value of works, materials or goods comprised in a contract as in Royden (M) Sdn Bhd v Syarikat Pembenaan Yeoh Tiong Lay Sdn Bhd[1]. In a simple words, payment can be a consideration in terms of money for works that Contractor had carried out and material delivered to site accordance to the contract. Contractually it can be said that the money must be paid by Employer promptly of fully unless there are specific reasons for delaying or withholding it. Don’t waste time! Our writers will create an original "Payments in Construction Law" essay for you Create order While interim payment can be defined as provisional or short-term payments made progressively to a Contractor at weekly, bi-weekly or monthly intervals based on periodical estimated value of work that the Contractor has carried out (Siti Suhana Rosli, 2010). Interim payment is also known as progress payment or stage payment (Clause 30.2, PAM 2006). The major standard forms of construction contracts used in Malaysia namely the PWD 203A (2007), PAM (1998/2006) and CIDB (2000), contain provisions for payments to be made against Interim Certificates issued periodically by the Architects, Superintending Officer (S.O.) or Clientà ¢Ã¢â€š ¬Ã¢â€ž ¢s Representative or Contract Administrator as the case may be. The provisions give the Contractor the right to be paid upon the issuance of the interim certificate and compel the Employer to pay the Contractor the certified amount (Harban Sigh, 2003). In the event of late payment or non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment made by Employer, Contractor ma y have several option either to determine the contract, suspension of work at site or slowing down the work. There is a provision under PAM 2006 Clause 30.7 stated that Contractor has right to suspend the works until payment due is made and a written notice must be delivered by hand or registered post to Employer. While Clause 42.10 of CIDB 2000 allows Contractor to give a notice to Employer about his intention to suspend the works and if the Employer still did not made the payment, Contractor may suspends wholly or partly the works or reduce the rate of execution of works. Contractor also entitled for extension of time and if any loss or damages incurred arising from such suspension of works. In next section 2 cases of Determination by the Contractor will be discussed. DISCUSSION Case: Dataran Rentas Sdn. Bhd. v BMC Construction Sdn. Bhd. (2008) This case is between appellant (Dataran Rentas Sdn Bhd) against the decision of the High Court at Penang on a winding up petition filed by respondent (BMC Construction Sdn Bhd) against the appellant the High Court had made the following orders:- (i) that the appellant be wound up pursuant to the provisions of the Companies Act 1965; (ii) that the Official Receiver be appointed the provisional liquidator of the appellant; and (iii) that the costs of the petition be paid out of the assets of the appellant. Facts The relevant background facts leading to the filing of the winding-up petition by the respondent against the appellant are as follows: (1) The respondentà ¢Ã¢â€š ¬Ã¢â€ž ¢s claim against the appellant is for the sum of RM173, 096.18 due and owing by the appellant to the respondent pursuant to four interim certificates issued under a building contract entered into between the two parties. (2) By a letter of award dated 29.7.1997, the appellant awarded a bu ilding contract to the respondent. (3) Pursuant to the letter of award, it was agreed that the terms and conditions of contract are as per PAM Standard Form Building Contract 1969 Edition (without Quantities) [à ¢Ã¢â€š ¬Ã…“PAM Conditionsà ¢Ã¢â€š ¬Ã‚ ]. (4) Pursuant to Clause 30(1) of the PAM Conditions read together with the Appendix, the appellant was contractually obliged to pay the respondent the amount due under Interim Certificate within thirty days. (5) The appellant has failed to pay the following interim certificates within the stipulated time stated under Clause 30(1) of the PAM Conditions. CERTIFICATE NO. DATES AMOUNT DUE 5 15.1.1998 RM 23,876.74 6 15.2.1998 RM 23,986.80 7 16.3.1998 RM 68,086.41 8 16.4.1998 RM 57,146.23 RM173,096.18 Held It was further held that, as per Gopal Sri Ram JCA, on a true construction of clauses 26(1)(a) and 30(1) of the contract, the appellants obligation to make payment on an interim certificate was a fundamental term or a primary obligation. Court order that the deposits be paid to the respondent (BMC Construction Sdn. Bhd.) to account of taxed costs. Conclusion Case: D. R. Bradley (Cable Jointing) Limited v Jefco Mechanical Services Limited (1988) Facts Jefco were main contractor for the refurbishment of Islington Town Hall. Bradley was appointed as domestic subcontractor to Jefco for the electrical installation. The subcontract between Bradley Jefco were made verbally, no specific payment terms were accepted but it was agreed that interim payment would be made. Bradley made various request for payment but none were met in full. On 29th October 1985, Bradley made another application of interim payment  £27, 140.00 and a notice was given in the event of non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment, Bradley would leave site. No payment was made and on 12th December 1985, Bradley left the site and litigation commenced. Held Underpayments by Jefco did not amount to a repudiatory breach, but the non-payment of the last application was such a breach, as it reasonably shattered Bradleyà ¢Ã¢â€š ¬Ã¢â€ž ¢s confidence of being paid. Bradley was entitled to consider the contract at an end and to be terminated. Conclusion In the absence of express clause in the contract, non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment could give rise to a contractor or subcontractorà ¢Ã¢â€š ¬Ã¢â€ž ¢s entitlement to determine, if such non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment undermined the core of the contract. Nevertheless, in the absence of an express clause giving a right to suspend work, no such right exists in common law. The options is either to carry on working, or determine the contract as the only other remedy if the non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment à ¢Ã¢â€š ¬Ã‹Å"shatter confidenceà ¢Ã¢â€š ¬Ã¢â€ž ¢. CONCLUSION The non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment event is a common case occurred in a construction industry. In any circumstances, Contractor cannot suspend works or slow down the progress work in event of late payment or non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment. The Employer entitled to terminate the employment contract based on Clause 51 (a) (ii) PWD 203A, à ¢Ã¢â€š ¬Ã…“the Contractor fails to proceed regularly and diligently with the workà ¢Ã¢â€š ¬Ã‚  if proven Contractor slow down the progress work at site. In Kah Seng Construction Sdn.Bhd. v Selsin Development Sdn.Bhd (1997) and Canterbury Pipe Lines v Christchurch Drainage (1986), the court held that no implied of temporary suspension owing of non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment from Employer. However, in PAM 2006, and CIDB 2000, Clause 42.10 there are provision that allows suspension of work in event of non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment. There are provisions under PAM 2006 and CIDB 2000 standard form of contract allowing Contractor to determine his emp loyment in the event of non à ¢Ã¢â€š ¬Ã¢â‚¬Å" payment by the Employer. Under the common law, termination only permissible if proven repudiation of primary obligation by Employer. Reference is made to the cases of Ban Hong Joo Mines v Chen Yap Ltd (1969), and Yong Mok Hin v United Malay States Sugar Industries Ltd (1967). [1] [1992]1 MLJ 33

Tuesday, December 17, 2019

Christopher Columbus s First Encounters Essay - 1294 Words

Kindness in today’s society only gets one so far. The saying nice guys always finish last might simply hold some truth. In â€Å"First Encounters,† we gain insight about how the initial explores of America interacted with the natives. European ideology had no room for this other hemisphere or in fact the people that lived there. The text we go on to read describes just how gruesome this time period truly was. The Natives were referred to as â€Å"savages.† They currently we re at war with themselves during the arrival of the westerners, increasing the body count even higher. Then we proceed on to read about Christopher Columbus’s personality through his letters to Luis De Santangel and his role during the exploration of this newly discovered land. Christopher Columbus was always pictured in my mind as a nobleman of high morale. At least that s how the teachers in early on stages of schooling preached to me. Now realizing the truths, he s just like many men I’ve met in society over that past few years, greedy, self-centered, and thirsty for dominance and power. Men and women across the globe are willing to go to extreme measure to make sure they get ahead in society, this was the case for Christopher Columbus. While reading both of these passages I couldn t help but think of one movie, The Wolf of Wall Street. When initially comparing Jordan Belfort to Christopher Columbus some might be skeptical. Truly though they share the same characteristics. In order to be dominant leadersShow MoreRelatedThe Pioneering Exploration Of The Caribbean Islands By Christopher Columbus1027 Words   |  5 PagesIntroduction The pioneering exploration of the Caribbean Islands by Christopher Columbus led to the first European contact of Taino Indians in that region. This encounter resulted in the Taino Indians being traded, yet opened the South Atlantic and Caribbean for future exploration and eventual colonization. The First Voyage of Christopher Columbus’ kicked off his legacy. Find the Funds Columbus had a different idea: Why not sail west across the Atlantic instead of around the massive African continentRead More The Portrayal of Christopher Columbus in Elementary School Education2347 Words   |  10 Pages Christopher Columbus has been portrayed in different ways at various times throughout history. In his own time he was not famous for discovering a new land, but hundreds of years later he is. Slightly over one hundred years ago the United States proudly celebrated the quatercentury. Approximately 24 million people attended a great international exposition in Chicago marking the event (Thernstrom, 1992). In stark contrast is the controversy that was ignited over the 500 year anniversaryRead MoreChristopher Columbus : A Hero Or Hero?1445 Words   |  6 Pages Christopher Columbus was he a hero or was he a villain? As attitudes change throughout the years and new discoveries are being made, history is constantly being rewritten. In the recent years, there has been much controversy over the â€Å"achievements† of the great admiral Christopher Columbus. There have also been many books, articles, and historians that have described him as â€Å"one of the greatest mariners in history, a visionary genius, a national hero, a failed administrator, a naive entrepreneurRead MoreSummary : Columbus, The Indians, And Human Progress1389 Words   |  6 PagesDate: August 8, 2016 Period: 1 Chapter 1: Columbus, the Indians, and Human Progress 1. Important People In this section, you will list the important people that are presented in the chapter with a short description of that individual. (Approximately one sentence each) Arawak people- Natives of the Bahamas Islands that Christopher Columbus came upon; they are known for their hospitality and their belief in sharing. Christopher Columbus- A merchant s clerk from the Italian city of Genoa, a part-timeRead MoreCultural Exchange Between Europeans And Native Americans957 Words   |  4 PagesAmericas. The Europeans first came to the Americas looking for riches like gold and land. When they got here they found Native Americans along with land. According to Thomas Hariot and Christopher Columbus, the Indians were poor and easily persuaded. They thought that they could be easily influenced by European culture. Thomas Hariot said â€Å"they shoulde desire our friendships and love, and have the greater respect for pleasing and obeying us.† (2-4) Christopher Columbus said â€Å"They should be goodRead More The Re-evaluation of Christopher Columbus Essay2325 Words   |  10 Pagesheroes may become hated villains. In recent years, this has been the case with the great admiral, Christopher Columbus. For years, the admiral was considered to be, by historians (working primarily from historical documents created by Europeans, with a decidedly Euro centric slant), as well as by the white, euro-American population, to be the great discoverer of the New World. Christopher Columbus changed the way man looked at his world, creating a new global perspective, and opening the floodgatesRead MoreChristopher Columbus : New Trade Routes Essay2254 Words   |  10 PagesChristopher Columbus was determined to find new trade routes to India and so, in 1492, after gaining permission he set out in order to accomplish this task. However, what Christopher Columbus would actually encounter was not new trades routes to India, but a whole â€Å"new† world. What exists, however, when you travel to a new country is the possibility of a language barrier between you and the native individuals. This barrier existed when Christopher Columbus first made contact with the native indigenousRead MoreEffects Of European Expansion On America1407 Words   |  6 PagesGod, and the strategic needs that their country may require. Among the first well known European explorers, Christopher Columbus, an experienced voyager, discovered a â€Å"New World† that he claimed for Spain in 1492. He had named the indigenous peoples that he and his crew discovered Indians, as he had originally thought that he discovered a new passage to India. Soon new discoveries had occurred left and right after Columbus and his expedition for new lands, especially as explorers sought for a newRead MoreCultural Impact Of The Columbian Exchange1153 Words   |  5 Pagesthat created a great cultural impact. This paper will focus on the cultural impact that food had in the world, and how much Native American food contributed to the economy and culture of the entire planet. The Columbian Exchange started after Christopher Columbus’ â€Å"discovery† in 1942 of a New World. This discovery lent to the entire Western world to gain and to grow with years of expansion and discovery. The Columbian Exchange was a worldwide phenomenon that transfer plants, animals, technology, ideasRead MoreAnalysis of A People’s History of the United States by Howard Zinn696 Words   |  3 PagesPeople’s History begins with a recounting of first encounters of the Native people with Christopher Columbus. Zinn’s opinions of the reality of these first encounters are substantially different from the stories we hear as children. We find Columbus traditionally depicted as a peaceful explorer who, after â€Å"discovering† a new land, made friends with the native people. Utilizing Columbus’ own journals as well as the writings of the time, Zinn shows us a Columbus who is a greedy man with a lust for gold

Monday, December 9, 2019

Baker V Gilbert Kralc Wholesale Pty Ltd

Question: Discuss about theBaker V Gilbert for Kralc Wholesale Pty Ltd. Answer: Introduction Issue: This assignment will summarize the case which was between Baker and Gilbert. The judgement was given by the Court on 23rd May 2003. The judgement was given by Hodgson JA. The parties involved in this case were Karen Gilbert who was the first respondent, Kralc Wholesale Pty Ltd who was the second respondent and Nylex Industrial Products Pty Ltd who was the third respondent. In this case Karen Gilbert got seriously injured when she landed awkwardly after jumping off an unstable footpale attached to a swimming pool ladder at the premises of the appellant. Appellant, Garling DCJ was not careful in inspecting and maintaining the ladder adequately. Since it was his fault damages were being awarded to Gilbert. Appeal was made by the appellant that Garling DCJ had wrongly held himself for breach of duty of care which he owed to the first respondent. After a certain investigation it was found out that the footpale was not stable and such instability was mainly caused by the tightened b olts. In the Australian Law there was nowhere mentioned that householders will be considered negligent if they are unaware about any defect in their property. Gilbert was swimming in the pool with the permission of Baker.[1] After swimming when she was going to climb the ladder then she fell and got seriously injured. Then she had alleged on several grounds that Baker was negligent in maintain the ladder properly. If he would have maintained the ladder properly then this incident would not have occurred. Appeal was made on several grounds but it mainly fall under the below two categories: Garling DCJ unable to find about the instability of the footpale and it was mainly caused by the inadequate tightened bolts. Garling DCJ was also erred in finding that as an occupier of the premises Mr. Baker should have maintained or inspected the footpale and the ladder.[2] Rule: in this case Common law of negligence would be applicable. Common Law simply says that if many persons enter the premises of the occupier then it is his duty to take care of those premises. They are in the premises which belong to the occupier so he should not be negligent in performing his duties. Even the tort of negligence would be applied in this case. Generally torts are created by common law and these statutory wrongs are analogous to torts. Tort is generally considered as a crime and all the claims in tort are civil claims which are bought up by the individuals concerned. Torts can be committed by anyone whether its individual or companies.[3] Tort liability includes both vicarious liability and personal liability. It includes false improvement, assault, battery and a very expensive tort of negligence. Negligence can happen anywhere, whether it is on roads, or it is in somebodys place or anywhere else. It is necessary that in all case of torts damages will be awarded. It will depend upon case to case basis. Generally people have the right for any legal distress if they can prove the probabilities that they have been a victim of tort. In some of the cases victim can even ask for an injunction from the courts so that tort can be prevented.[4] Application: now after understanding the issue and provisions relating to the case we will understand how these provisions is applied in this case. The courts judgement will also be discussed here. The main problem was that the nut was not tightened up to the coaming properly, and so the footpale was not stable. This resulted in the fall of Gilbert. Garling DJ was simply claiming that the footpale was not properly fixed which was very critical for the people who were swimming there. He stated that it was the premises of Mr. Baker and so he responsible for the safety of the people coming in his premises. But unfortunately the footpale was not stable and Gilbert got hurt very badly. So Mr. Baker had breached his duty of care. He should have been careful since he owed a duty of care to all the people in the swimming pool. Some of the cases were very similar to this case. One of the cases which were very similar to this one was the case between Short v Barret. In this case a visitor came to his friends place where he fell of a timber deck balcony because one of the planks on the side of the balcony gave away. The house owner was simply not aware about this defect in his balcony.[5] There was another case between Stannous v Graham where plaintiff had rented the premises of the defendant as a holiday flat. The problem in this case was that there were loose steps in the premises which even the defendant was unaware. Due to this plaintiff had fallen and had several personal injuries. It was finally concluded that defendant was not to blame since he was not aware about the defect in the premises. Hence on the basis of this even Court had decline to impose and tortious duty on the owner to inspect the premises for the purpose of discovering some defects which were not known. On the basis of the above two cases I would want to support the defendant that is Baker. Gilbert came in the premises of Baker and she got injured since the footplate was not stable. Mr Bakers liability was given in the judgement of Deane in Hackshaw v Shaw and was also approved by the High Court in Australian Safeway Stores Pty Limited v Zaluzna. The first most important thing to determine is to whether the defendant owed any duty of care under the ordinary principles of the negligence to the plaintiff. Since defendant owes a duty to the plaintiff this means that there must be a degree of proximity of relationship. So there would be a reasonable risk of injury to the visitor who is a member. Breach of the duty would depend upon on a situation in which a reasonable person would do to give response to the foreseeable risk. In the case of Short v Barret, before finding that there was no negligence from the side of the occupier it was seen that balcony showed that there were no signs of crack and there was indication that the balcony was unsafe. It was a sudden incident which evens the occupier didnt expect. Defendant received no warning that the balcony would be unsafe. It is not always possible to give warning to everyone; sometimes warnings can be implied from the circumstances.[6] Conclusion: The conclusion reached by the judge was that it would not uphold the appeal by the appellant. Mr Baker was responsible for the injury which was caused to Gilbert. He had breached the duty of care. The judge had decided to dismiss the second appeal with costs. Garling was responsible to find out the appellant responsible for any consequences that had raised in the negligence of ladders maintenance.[7] During the day when Gilbert got hurt Baker had inspected the pool and have noticed that there were some issue with the footplate. This shows that there was a sign of warning that something was wrong with the footplate. So he should have given warnings to all the people who went for swimming. But unfortunately he failed to give any warnings to anyone. Due to this Gilbert got hurt and suffered with several injuries. Court had also find out that there was a gap between the footplate and coaming and so this was the sign which should have given to all the people swimming in the po ol. Even this was accepted by Baker that the bolts were not adequately tightened. He had noticed himself that the ladder needed an inspection just before the accident. But unfortunately he had failed to do so and ultimately Gilbert got injured. This case was very different than the case examples which were given above. In the above cases occupiers were not at all aware about the defect in their premises. If they were aware that some signs of warnings must have been given by them to the plaintiff. In this case Baker was aware about the situation but still his dint informed about it to all the people. So he was wrong in this case and had breached the duty of care, He was proved negligent in this case and so the Court had dismissed the second ground of appeal and had also proposed that the appeal should be dismissed with costs.[8] References Baker G, Gilbert G and Petersen S, 'Book Reviews' (2001) 60 Art Journal Baker R,The Norton Book Of Light Verse(Norton 1986) Baker V Gilbert' (prezi.com, 2016) https://prezi.com/-_yutnr81lge/baker-v-gilbert/ accessed 24 September 2016 'BAKER V. Gilbert, Francis, Baker Assoc., Inc' (Casetext.com, 2016) https://casetext.com/case/baker-v-gilbert-francis-baker-assoc-inc accessed 24 September 2016 Barret R and Daudon M, 'Transformation Of Acridines And Azepines Into The Corresponding 3-Oxo-Heterocycles By Means Of Hypervalent Aromatic Iodine Compounds' (1991) 122 Monatshefte fà ¯Ã‚ ¿Ã‚ ½r Chemie Chemical Monthly Markesinis B, Deakin S and Dias R,Tort Law(Clarendon Press 1994) New South Wales Court Of Appeal' (https://www.vrlaw.com.au, 2016) https://www.vrlaw.com.au/cases/pdfs/200403010934400.gilbert.pdf accessed 24 September 2016 'Tort: Negligence: Proximate Cause' (1904) 3 Michigan Law Review.

Monday, December 2, 2019

Womens role in family Essay Example For Students

Womens role in family Essay We have had our worst time. Women, for many years were kept hidden inside the dusty den of depravity. They were not allowed to go to a school. Home was their world. Outside world were meant only for men, the bread-earners of a family. Hence, they were wrapped by such a murky life that they remained disregarded for many years. But things are different now. Women induced as much courage within themselves so as to unveil their wrap to the society. Womens liberation group and what not have emerged since then. They have a lot of demands. They want proper education for the girl child. We will write a custom essay on Womens role in family specifically for you for only $16.38 $13.9/page Order now They want status at par with men in every respect possible. But whom are they asking their demands to? Men. Thats right. Men. And to me, by activating themselves through this process of liberation, they are in fact intensifying the superior contemplation of their opposite sex. There is no doubt that they have been successful to a certain extent in reaching their goals. Now women go to schools. They can now educate themselves as much as they want. If not a lot, then some are acquiring high and respectable positions in work places. But since it is a fact that even after all these accomplishments, there still exits women liberation groups, makes us think that all of womens demands are not fulfilled. And it will never be fulfilled if they continue this way. That is because whenever they are demanding something, they are actually giving men a choice. If it is fruitful to a man to educate a girl child, then he would consider it, or else they wont. In other words, women havent really been successful in changing mans attitude towards them. So, what should they do now? I think that the best way to deal with this issue would be to make the man realize of their own importance to the society as a whole. What role do women play in the world? My mother is a woman and I cant disregard her influence on my life. She is a great person to me. And I only have positive thoughts about her. Likewise, every woman should play a key role in establishing a warm and solid link with her child so that in future when the child grows up to be a man, he would realize the importance of a mother in their household. Household. Thats the word I still prefer in regard to women. Women truly plays a major role in the household. To me, a family would be perfect and happy if the man plays the role of a bread earner for the family and the woman plays the role of a household mother. Here the meaning of the word mother goes a lot beyond our typical knowledge of motherhood. She wont be the mother only to her child, rather to her family and to her society as a whole. I know that it is not very heard of in the western part of the world. But in the east, where I was born and brought up, injected within me the idea that a woman is a mother whose responsibilities lie strictly surrounding the well being of the family. And if that requires a mother to work outside the home, she should do that, not for the sake of doing it, rather for the betterment of the household she belongs. Even though it may apparently appear to be outrageously wrong to adopt my above suggestion, but, believe me, it works. I truly do not want women to enjoy less freedom than their male counterpart. Neither do I want women to be suppressed from the proper rights and privileges that our society has to offer to an individual. But, just think about it. .u1186da32b26a8918b4cd04f514b37ae6 , .u1186da32b26a8918b4cd04f514b37ae6 .postImageUrl , .u1186da32b26a8918b4cd04f514b37ae6 .centered-text-area { min-height: 80px; position: relative; } .u1186da32b26a8918b4cd04f514b37ae6 , .u1186da32b26a8918b4cd04f514b37ae6:hover , .u1186da32b26a8918b4cd04f514b37ae6:visited , .u1186da32b26a8918b4cd04f514b37ae6:active { border:0!important; } .u1186da32b26a8918b4cd04f514b37ae6 .clearfix:after { content: ""; display: table; clear: both; } .u1186da32b26a8918b4cd04f514b37ae6 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u1186da32b26a8918b4cd04f514b37ae6:active , .u1186da32b26a8918b4cd04f514b37ae6:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u1186da32b26a8918b4cd04f514b37ae6 .centered-text-area { width: 100%; position: relative ; } .u1186da32b26a8918b4cd04f514b37ae6 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u1186da32b26a8918b4cd04f514b37ae6 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u1186da32b26a8918b4cd04f514b37ae6 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u1186da32b26a8918b4cd04f514b37ae6:hover .ctaButton { background-color: #34495E!important; } .u1186da32b26a8918b4cd04f514b37ae6 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u1186da32b26a8918b4cd04f514b37ae6 .u1186da32b26a8918b4cd04f514b37ae6-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u1186da32b26a8918b4cd04f514b37ae6:after { content: ""; display: block; clear: both; } READ: Autism Essay Bibliography:None