title: Goldcrest

text: The goldcrest is the smallest European bird, in length, with a wingspan and a weight of . It is similar in appearance to a warbler, with olive-green upper-parts, buff-white underparts, two white wing bars, and a plain face with conspicuous black irises. The crown of the head has black sides and a narrow black front, and a bright crest, yellow with an orange centre in the male, and entirely yellow in the female; the crest is erected in display, making the distinctive orange stripe of the male much more conspicuous. The small, thin bill is black, and the legs are dark flesh-brown.


title: Goldcrest

text: Apart from the crest colour, the sexes are alike, although in fresh plumage, the female may have very slightly paler upper-parts and greyer underparts than the adult male. The juvenile is similar to the adult, but has duller upper-parts and lacks the coloured crown. Although the tail and flight feathers may be retained into the first winter, by then the young birds are almost indistinguishable from adults in the field. The flight is distinctive; it consists of whirring wing-beats with occasional sudden changes of direction. Shorter flights while feeding are a mix of dashing and fluttering with frequent hovering. It moves restlessly among foliage, regularly creeping on branches and up and down trunks.


title: Goldcrest

text: The goldcrest is usually easily distinguished from other small birds in its range, but poor views could possibly lead to confusion with the common firecrest or yellow-browed warbler. The adult common firecrest has a distinguishing face pattern showing a bright white supercilium (eyebrow) and black eye-stripe, and the juvenile usually shows enough of this face pattern to be readily distinguished from the plain-faced goldcrest. The yellow-browed warbler has a yellowish supercilium and pale crown stripe, so also shows a different head pattern.


title: Goldcrest

text: The ruby-crowned kinglet, an American "Regulus" species and a potential vagrant in Europe, could be more difficult to distinguish. It has a plain face like its Old World cousin, but the male has a red crest without any yellow or a black border. Female and juvenile ruby-crowned kinglets lack the ruby-red crown patch, but compared with the similarly crestless juvenile goldcrest, the American bird is larger in size, has an obvious whitish eyering, and yellowish wing bars.


title: Goldcrest

text: The typical contact call of the goldcrest is a thin, high-pitched "zee" given at intervals of 1–4 seconds, with all the notes at the same pitch. It sometimes has a more clipped ending, or is delivered more rapidly. The call is higher and less rough than that of the firecrest. The song of the male goldcrest is a very high, thin double note "cedar", repeated 5–7 times and ending in a flourish, "". The entire song lasts 3–4 seconds and is repeated 5–7 times a minute. This song, often uttered while the male is foraging, can be heard in most months of the year. There is also a subdued rambling subsong. Male goldcrests sometimes show a territorial response to recordings of the songs or calls of the common firecrest, but the reverse is apparently not true, since the songs of the common firecrest are simpler in construction than those of its relatives.


title: Goldcrest

text: The songs of mainland goldcrests vary only slightly across their range and consist of a single song type, but much more divergence has occurred in the isolated Macaronesian populations. Not only are there variations between islands and within an island, but individual males on the Azores can have up to three song types. The dialects on the Azores fall into two main groups, neither of which elicited a response from male European goldcrests in playback experiments. There are also two main dialect groups on the Canary islands, a widespread group similar to the European version, and another that is restricted to the mountains of Tenerife. The song variations have been used to investigate the colonisation pattern of the Macaronesian islands by goldcrests, and identified a previously unknown subspecies.


title: Goldcrest

text: The kinglets are a small group of birds sometimes included in the Old World warblers, but frequently given family status, especially as recent research shows that despite superficial similarities, they are phylogenetically remote from the warblers. The names of the family Regulidae, and the genus "Regulus", are derived from the Latin , a diminutive of , a king. The goldcrest was first described by Carl Linnaeus in his in 1758 as "Motacilla regulus" (characterised as ). It was moved to the warbler genus "Sylvia" by English naturalist John Latham in 1790, and to its current genus by French zoologist Georges Cuvier in 1800.


title: Goldcrest

text: The relationships of the flamecrest or Taiwan firecrest ("Regulus goodfellowi") of Taiwan have also been a source of much debate. It is sometimes viewed as a race of firecrest, but its territorial song resembles those of the Himalayan races of goldcrest, and genetic data show that it is the closest relative of that species, and, despite its alternative name, only distantly related to the firecrest. The flamecrest diverged from the goldcrest 3.0–3.1 mya (million years ago).


title: Goldcrest

text: Several subspecies of the goldcrest have been described. In continental Eurasia, there are nine generally accepted and very similar subspecies, differing only in details such as plumage shade. At the genetic level, the two Central Asian forms, "R. r. sikkimensis" and "R. r. himalayensis", are very close to each other, and have differentiated only in the recent past, but they diverged from the western subspecies around 2.8 mya.


title: Goldcrest

text: Two groups of goldcrest taxa are found on the Atlantic islands of Macaronesia. Birds on the Canary Islands are ancient colonists, whereas those on the Azores are of more recent origin. There are no goldcrests on Madeira, where the Madeira firecrest is the only "Regulus" species.


title: Goldcrest

text: The Canary Islands were colonised in two waves. The first step was the occupation of Tenerife and La Gomera 1.9–2.3 million years ago, followed by a separate invasion of El Hierro and La Palma 1.3–1.8 mya.


title: Goldcrest

text: Birds from the Canary Islands are particularly distinctive having a black forehead, pink-buff underparts and a darker closed wing, and have been sometimes treated either as a subspecies of the common firecrest or as a different "Regulus" species altogether. They were sometimes called the Tenerife goldcrest, no matter which of the islands they lived on; however, a 2006 study of the vocalisations of these birds indicate that they actually comprise two subspecies of the goldcrest that are separable on voice; "R. r. teneriffae" occurring on Tenerife and the newly described subspecies, "R. r. ellenthalerae", the western Canary Islands goldcrest, occurring on the smaller islands of La Palma and El Hierro.


title: Goldcrest

text: Differences in songs, genetics and morphology suggests that the Azores were colonised in a single invasion in the late Pleistocene, about 100,000 years ago. It is likely that the initial colonisation was of the easternmost islands, with a subsequent spread to the central and western island groups from the western caldera of São Miguel, where both eastern and western song types are found.


title: Goldcrest

text: There are a few Pleistocene (2.6 million to 12,000 years BP) records from Europe of extant "Regulus" species, mostly goldcrests or unidentifiable to species. The only fossil of an extinct "Regulus" is a left ulna from 2.6–1.95 mya in Bulgaria, which was identified as belonging to an extinct species, "Regulus bulgaricus". The goldcrest lineage diverged from this apparent ancestor of the common firecrest in the Middle Pleistocene.


title: Goldcrest

text: The goldcrest breeds in mature lowland and mountain coniferous woodlands, mainly up to , and occasionally to . It uses spruce, larch, Scots pine, silver fir and mountain pine, and in man-made landscapes also introduced conifers such as douglas fir. Breeding densities of up to 591 pairs per square km (1,530 pairs per square mile) have been recorded in Norway spruce in Ireland, and goldcrests constituted over 60% of all birds found in Welsh Douglas fir and Norway spruce plantations. Broad-leaved woods are used only when some spruce or firs are also present. Sites such as parks and cemeteries are used only when they offer suitable conifers that are not otherwise locally available. The height and nature of any undergrowth is irrelevant.


title: Goldcrest

text: Unlike more specialised birds such as the Eurasian nuthatch and the Eurasian treecreeper, both of which forage on tree trunks, the kinglets do not need large woodlands, and their population density is independent of forest size. Once breeding is over, this species will readily move into deciduous trees and shrubs, heathland and similar more open habitats.


title: Goldcrest

text: The Tenerife subspecies occurs in the mountain region previously occupied by laurisilva, but now dominated by tree heaths. It is common only in that habitat, becoming rare in pine forest, where it occurs only where tree-heath is also available.


title: Goldcrest

text: The goldcrest has a huge range in Eurasia, breeding from Macaronesia to Japan. It is common in middle and northern temperate and boreal latitudes of Europe, between the July isotherms, and thus predominantly in cooler climates than the firecrest. Further east it occurs discontinuously through southern Siberia to Sakhalin and Japan, in the Tian Shan mountains, northern Iran, and from the Himalayas east to central China.


title: Goldcrest

text: This species has bred in Iceland since about 1999, and was widespread by 2004, although numbers are affected by hard winters. Breeding occurs intermittently in the Faroes. The goldcrest has occurred as a vagrant in Jordan and Morocco.


title: Goldcrest

text: This species is partly migratory, northernmost populations deserting their breeding areas in winter. Birds winter in Europe and Asia south of the breeding range. Birds in northern Fennoscandia and Russia vacate their territories between late August and early November, with most leaving in late September to mid-October as the first cold weather arrives. Adverse conditions may lead to disorientation, large numbers gathering on ships on overcast or wet nights. Large influxes include 15,000 birds on the Isle of May in October 1982, and nearly 21,000 birds through a single site in Latvia during September and October 1983. Spring migration is complete by late March on the Mediterranean islands, but continues to late April or early May in northern Europe. The spring passage is much lighter than in autumn, suggesting high mortality on migration.


title: Goldcrest

text: A study in the Baltic region showed that northern goldcrests were more likely to migrate, and increased their body mass beforehand; non-migratory southern birds did not increase their fat reserves. The travel speed of migrating goldcrests increased for those leaving later in the autumn, and was greater for the northernmost populations. Migration was faster on routes that crossed the Baltic Sea than on coastal routes, and the birds with the largest fat reserves travelled at the highest speeds. The ability to lay down fat is adversely affected in this tiny bird by poor health. In Hungary, goldcrests stopping temporarily on migration were mostly found in scrub, including blackthorn, hawthorn and pear, which provided some protection from sparrowhawks. Females migrated slightly earlier than males, but overall there were more males, with an average sex ratio of 1.6:1. Goldcrests can fly in one day, although they keep at a lower level in heavy headwinds. This is a tame and inquisitive bird, and tired migrants will land near or on humans, sometimes searching for food on their clothing.


title: Goldcrest

text: The North Atlantic oscillation is an atmospheric phenomenon affecting the weather in Western Europe. When the atmospheric pressure variations in the North Atlantic are large, the springs in Europe are warmer. This brings forward the northward migration of those bird species (including the goldcrest) that winter mainly within western or southern Europe. A general climatic change resulting in more frequent positive North Atlantic oscillation events has led to earlier spring migration of these short-distance migrants since the 1980s. The warmer spring weather brings on plant growth, thus preparing the habitat for returning migrants. The effect is greatest in western and central Europe.


title: Goldcrest

text: The goldcrest is monogamous. The male sings during the breeding season, usually while foraging rather than from a perch. It has a display involving bowing its head towards another bird and raising the coloured crest. Firecrests will sometimes defend their territories against goldcrests, but the amount of actual competition between the species may not be very great. A Spanish study suggested that territorial conflicts between species, and other phenomena like males singing mixed or alternating songs, were most frequent when one species locally far outnumbered the other; in other circumstances, the two species learned to ignore each other's songs. However, in very small areas of conifers it is rare for the goldcrest and the firecrest to share territories; either one or the other is present, but not both. A male goldcrest will defend his territory against either species, sometimes including some firecrest phrases in his song.


title: Goldcrest

text: The goldcrest's nest is a well-insulated cup-shaped structure built in three layers. The nest's outer layer is made from moss, small twigs, cobwebs and lichen, the cobwebs also being used to attach the nest to the thin branches that support it. The middle layer is moss, which is lined by an inner layer of feathers and hair. The nest is larger, shallower and less compact than that of the firecrest, with an internal diameter of about , and is constructed by both sexes, although the female does most of the work. It is often suspended from a hanging branch, usually at no great height, although Eric Simms reported nests at heights from . One pair built their nest just above that of a sparrowhawk.


title: Goldcrest

text: Laying starts at the end of April into early May. The eggs are whitish with very indistinct buff, grey or brown markings at the broad end. The eggs are and weigh , of which 5% is shell. The clutch size in Europe is typically 9–11 eggs, but ranges from 6–13. The eggs are piled up in the nest and the female keeps the eggs warm with her brood patch and also by putting her warm legs into the middle of the pile between the eggs. Within a clutch the size of eggs increases gradually and the last laid egg may be 20% larger than the first egg. Second clutches, which are common, are laid usually while the first nest still has young. The male builds the second nest, then feeds the young in the first nest while the female is incubating in the second; when the first brood has fledged, he joins the female in feeding the second brood. The female goldcrest is not normally fed by her mate while incubating. She is a tight sitter, reluctant to leave the nest when disturbed, and has been recorded as continuing to attend the nest when it has been moved, or even when it is being held.


title: Goldcrest

text: The eggs are maintained at , the female regulating the temperature of the eggs by varying the time spent sitting. She leaves the nest more with increasing air temperature, and incubates more tightly when the light intensity is lower early and late in the day. The female incubates the eggs for 16 to 19 days to hatching, and broods the chicks, which fledge in a further 17 to 22 days later. Both parents feed the chicks and fledged young, and in very hot weather, the female has been noted as taking drops of water to her chicks in her bill. This species becomes sexually mature after one year, and has an annual adult mortality of over 80 percent giving a life expectancy of around eight months, which is the shortest for any bird apart from a few "Coturnix" species. There are nonetheless records of an individual surviving to 4 years 10 months, and even a report of a bird ringed in Winchester in the UK in 1989 and found dead in Morocco 7 years and 7 months later.


title: Goldcrest

text: Although their ranges overlap substantially, hybridisation between goldcrests and firecrests seems to be prevented by differences in courtship rituals and different facial patterns. Even in aviary studies in which a female goldcrest was given an artificial eyestripe to facilitate mating with a male firecrest, the chicks were never raised by the mixed pair, and appeared to be poorly adapted compared to the parent species.


title: Goldcrest

text: All "Regulus" species are almost exclusively insectivorous, preying on small arthropods with soft cuticles, such as springtails, aphids and spiders. They also feed on the cocoons and eggs of spiders and insects, and occasionally take pollen. All species will catch flying insects while hovering. Although the similarly sized goldcrest and firecrest are often found together, there are a number of factors that minimise direct competition for food. Goldcrests prefer smaller prey than common firecrests. Although both will take trapped insects from spider webs on autumn migration, firecrests will also eat the large orb-web spiders (on rare occasions kinglets have been found stuck in a spider web, either unable to move or dead).


title: Goldcrest

text: The goldcrest takes a wide variety of prey, especially spiders, caterpillars, bugs, springtails and flies. Larger prey such as oak bush crickets and tortrix moths may sometimes be taken. Flying insects are taken in hovering flight but not normally pursued; there is a record of a goldcrest attacking a large dragonfly in flight, only to be dragged along by the insect before releasing it unharmed. Goldcrests will occasionally feed on the ground among leaf-litter with tits. Non-animal food is rare, although goldcrests have been seen drinking sap from broken birch twigs together with tits and nuthatches.


title: Goldcrest

text: The goldcrest feeds in trees, frequently foraging on the undersides of branches and leaves. This is in contrast to the common firecrest, which mainly exploits the upper surface of branches in coniferous habitat and of leaves in deciduous trees. In winter, flocks of goldcrests cover a given distance at only one-third of the speed of common firecrests, taking the smallest prey items ignored by their relative. The differences in behaviour are facilitated by subtle morphological differences; firecrests have broader bills with longer rictal bristles (which protect a bird's eye from food items it is trying to capture), and these features reflect the larger prey taken by the species. The firecrest's less forked tail may reflect its longer episodes of hovering while hunting. Firecrests forage more often while on foot, and have a foot better adapted for perching, whereas the goldcrest's longer hind toe reflects its habit of moving vertically along branches while feeding. It also has deep furrows in the soles of its feet capable of gripping individual needles, while firecrests have a smoother surface.


title: Goldcrest

text: The goldcrest has much the same range and habitat preference as the common chiffchaff, and there is some evidence that high breeding densities of the kinglet depress the population of the warbler, although the converse is not true. There is no evidence that the species compete for territories, and in any case the chiffchaff is 50% heavier than the goldcrest. Nevertheless, there are 1.5 million breeding pairs of goldcrests in Finland, compared with 0.4 million breeding pairs of chiffchaffs, and only the kinglet has increased in numbers as the area of spruce woodland in the country has expanded. The goldcrest may be out-competing the warbler for food, especially as the larger bird faces more competition from other insectivores, including other "Phylloscopus" warblers. Both birds occur in similar forests, but the chiffchaff is found within of the forest edge, with the goldcrest breeding deeper in the woodland. Nevertheless, there is no conclusive evidence that the decline of the chiffchaff subspecies "Phylloscopus collybita abietinus" in parts of Finland is due to competition with the willow warbler and goldcrest.


title: Goldcrest

text: Outside the breeding season, small groups of goldcrests maintain exclusive winter feeding territories, which they defend against neighbouring groups. As they roam around their territory, they frequently join loose flocks of other wanderers such as tits and warblers. This kinglet, like other species that prefer mixed-species foraging flocks in winter, hunts over a greater range of heights and vegetation types than when feeding alone. For species that tend to feed in flocks, foraging success while in a flock was about twice that for solitary birds. A consequence of feeding in a flock is that foraging sites may be restricted to avoid competition with other species. In a Swedish study, coal tits and goldcrests foraged in the outer foliage, while the larger willow and crested tits used the inner canopy. In sites where the numbers of willow and crested tits was artificially reduced, goldcrests and coal tits extended their foraging to include the inner canopy, but did not do so where the larger tits were retained. In some areas, wintering birds have developed the habit of coming to feeding stations and bird tables to take fat, sometimes with warblers such as the common chiffchaff and blackcap.


title: Goldcrest

text: Several small passerine species survive freezing winter nights by inducing a lower metabolic rate and hypothermia, of a maximum of below normal body temperature, in order to reduce energy consumption overnight. However, in freezing conditions, it may be that for very small birds, including the tiny goldcrest, the energy economies of induced hypothermia may be insufficient to counterbalance the negative effects of hypothermia including the energy required to raise body temperature back to normal at dawn. Observations of five well-fed birds suggest that they maintain normal body temperatures during cold nights by metabolising fat laid down during the day, and that they actually use behavioural thermoregulation strategies, such as collective roosting in dense foliage or snow holes to survive winter nights. Two birds roosting together reduce their heat loss by a quarter, and three birds by a third. During an 18‑hour winter night, with temperatures as low as in the north of its range, goldcrests huddled together can each burn off fat equivalent to 20% of body weight to keep warm.


title: Goldcrest

text: Migrating birds rely largely on stored fat and they also metabolise protein as a supplementary source of energy. Those with a relatively large amount of fat, may make stops during migration of only 1–2 days; although they have lost weight since commencing their journey, they have enough energy reserves to reach the wintering areas. The proportion of migrating males increases as they travel south through Europe. There is competition within the species even during migration, and the larger and more aggressive males may get more food. Their death rate is therefore lower than that of the females both on the southward migration, and in resident populations.


title: Goldcrest

text: Throughout the goldcrest's range, the main predator of small woodland birds is the Eurasian sparrowhawk, which has a diet consisting of up to 98% of birds. Merlins, tawny and long-eared owls also hunt goldcrests. The erratic movements and flights of small woodland birds, which are vulnerable to attack while away from cover, may help to confuse their predators. The goldcrest has only very rarely been recorded as a host of the common cuckoo, a widespread European brood parasite.


title: Goldcrest

text: The goldcrest is a host of the widespread moorhen flea, "Dasypsyllus gallinulae", and of the louse "Philopterus reguli". The amblycerous mite "Ricinus frenatus" has been found on the eastern goldcrest subspecies, "R. r. japonensis" in Japan, and at the other end of the range in birds of the nominate subspecies on the Faroes and in Spain. These lice move over the host's body, and have strong mouthparts that pierce the host's skin so that they can feed on blood, and sometimes feather material. A number of feather mites have been recorded in the genus "Regulus"; these mites live on fungi growing on the feathers. The fungi found on the plumage may feed on the keratin of the outer feathers or on feather oil.


title: Goldcrest

text: The goldcrest has a large range, estimated at 13.2 million km (5.1 million mi) and a total population estimated at 80–200 million individuals, and it is therefore classed as least concern on the IUCN Red List. There was some northward range expansion in Scotland, Belgium, Norway, and Finland during the 20th century, assisted by the spread of conifer plantations. The population is currently stable, although there may be temporary marked declines in harsh winters.


title: Goldcrest

text: Although dense conifer growth can provide shelter for roosting at night, losses in hard winters can be heavy. In a Finnish study, only one-tenth of the wintering goldcrest population, which mainly fed on spiders, survived to spring. Each group roamed within a defined winter territory, and their winter survival depended on the density of the food supply. For these northern birds there is a trade off between staying put and risking starvation, or facing the perils of migration. Even in somewhat milder regions, where over-wintering is normal, exceptionally cold winters can cause such heavy losses that breeding populations take several years to recover. In 1930, the English ornithologist Thomas Coward wrote:


title: Goldcrest

text: Until the severe winter of 1916–17 the Goldcrest was abundant and widespread, nesting in all the wooded portions of our islands; in 1920 it could have little more than an obituary notice, for the nesting stock was practically "wiped out." ... and for some years, even as a winter visitor, the Goldcrest remained rare, absent from most of its nesting haunts. It is, however, now fully re-established.


title: Goldcrest

text: Conversely, populations can expand rapidly after a series of mild winters. In lowland Britain, there was an increase of 48% following the 1970/71 winter, with many pairs spreading into deciduous woodlands where they would not normally breed.


title: Goldcrest

text: Aristotle (384–322 BC) and Pliny (23–79 AD) both wrote about the legend of a contest among the birds to see who should be their king, the title to be awarded to the one that could fly highest. Initially, it looked as though the eagle would win easily, but as he began to tire, a small bird that had hidden under the eagle's tail feathers emerged to fly even higher and claimed the title. Following from this legend, in much European folklore the wren has been described as the "king of the birds" or as a flame bearer. However, these terms were also applied to the "Regulus" species, the fiery crowns of the goldcrest and firecrest making them more likely to be the original bearers of these titles, and, because of the legend's reference to the "smallest of birds" becoming king, the title was probably transferred to the equally tiny wren. The confusion was probably compounded by the similarity and consequent interchangeability of the Greek words for the wren ( , "king") and the crests ( , "kinglet"). In English, the association between the goldcrest and Eurasian wren may have been reinforced by the kinglet's old name of "gold-crested wren".


title: Goldcrest

text: It has had little other impact on literature, although it is the subject of Charles Tennyson Turner's short poem, "The Gold-crested Wren", first published in 1868. An old English name for the goldcrest is the "woodcock pilot", since migrating birds preceded the arrival of Eurasian woodcocks by a couple of days. There are unfounded legends that the goldcrest would hitch a ride in the feathers of the larger bird, and similar stories claimed that owls provided the transport. Suffolk fishermen called this bird "herring spink" or "tot o'er seas" because migrating goldcrests often landed on the rigging of herring boats out in the North Sea.


title: Knife play

text: Knife play is a form of consensual BDSM edgeplay involving knives, daggers, and swords as a source of physical and mental stimulation. Knives are typically used to cut away clothing, scratch the skin, remove wax after wax play, or simply provide sensual stimulation. Knife play can also be a form of temperature play or body modification.


title: Knife play

text: Knife play is sometimes, but not always, a form of fear play. The "victim" in some cases, is shown a sharp implement, and then blindfolded, and a blunt knife used on their skin (for example: the practice of insertive sex play without the certain knowledge of the submissive that an exchange of implements—blunt for sharp—has occurred. This is a form of fear play, yet it still maintains some degree of safety).


title: Knife play

text: For some, knife play can be highly erotic, as the physical and psychological reactions can be intense. It is also an activity that takes a great amount of care to learn properly. As with any sort of edge play that can potentially draw blood, there is the risk of passing diseases along. Also, there is the risk of cutting the wrong spot and causing excessive blood loss, or accidental stabbing.


title: Unified Multi-Purpose ID

text: The Unified Multi-Purpose ID (UMID) is a Philippine identity card which was introduced in 2010. The card was developed as a single card for the relations between several government-related agencies. The agency responsible for implementation is the Social Security System (SSS), and also Government Service Insurance System (GSIS), Philippine Health Insurance Corporation (PhilHealth), and the Pag-IBIG Fund (Home Development Mutual Fund) use the card. The card is also suggested to be used as Voter ID.


title: Unified Multi-Purpose ID

text: As part of the efforts of the Philippine government to establish a national identification document aimed at streamlining the identification systems of government agencies, a series of executive orders were enacted: Executive No. 420 signed on April 13, 2005 which institutionalized the UMID system, and Executive Order No. 700 signed on January 16, 2008 which directed the Social Security System to facilitate the ID systems of all government agencies and GOCCs.


title: Unified Multi-Purpose ID

text: The card features the text "Republic of the Philippines, Unified Multi-Purpose ID" on the top. Information fields on the front include:


title: Unified Multi-Purpose ID

text: The card also contains a picture of the bearer's face, signature and common reference number (CRN) or SSS number on the front.


title: Unified Multi-Purpose ID

text: At the back it contains the seals of the SSS, PhilHealth, Pag-IBIG, and GSIS. As of 2016, presence of these seals on UMID are not existing anymore.


title: Unified Multi-Purpose ID

text: In 2006, Kilusang Mayo Uno filed a case at the Supreme Court assailing the constitutionality of Executive Order (EO) 420, the legislation that mandated the creation of the UMID issued by President Gloria Macapagal Arroyo, on the grounds that it allegedly usurped legislative functions by the executive branch of government by, among others, using public funds not appropriated by Congress, and that it violated constitutional provisions on the right to privacy by Filipinos.


title: Unified Multi-Purpose ID

text: The Supreme Court denied their petition. It held that EO 420 did not require special appropriation because the existing ID card systems of government entities covered by EO 420 already have the proper appropriation or funding. It also did not apply to all branches of government and the act of getting one is not compulsory on all citizens. Therefore, it held, that EO 420 did not establish a national ID system in the Philippines. Additionally, the Court said, "If government entities under the Executive department decide to unify their existing ID data collection and ID card issuance systems to achieve savings, efficiency, compatibility and convenience, such act does not involve the exercise of any legislative power."


title: Unified Multi-Purpose ID

text: As regards the people's right to privacy, the Court held that such right does not bar the adoption of reasonable ID systems by government entities. It noted that "the GSIS, SSS, LTO, Philhealth and other government entities have been issuing ID cards in the performance of their governmental functions" and there have been no complaints from the public that these entities violate their right to privacy. It also mentioned that EO 420 authorizes the collection and recording of only 14 specific data while prior to its issuance, government agencies had a free hand to determine the kind, nature and extent of data to be collected and stored for their ID systems. Furthermore, the Court held that EO 420 contains provisions that institute safeguards to protect the collected data's confidentiality.


title: Helsinki Olympic Stadium

text: The Helsinki Olympic Stadium (; ), located in the Töölö district about from the centre of the Finnish capital Helsinki, is the largest stadium in the country, nowadays mainly used for hosting sports events and big concerts. The stadium is best known for being the centre of activities in the 1952 Summer Olympics. During those games, it hosted athletics, equestrian show jumping, and the football finals.


title: Helsinki Olympic Stadium

text: The stadium was also the venue for the first Bandy World Championship in 1957, the first and 10th World Athletics Championships, in 1983 and 2005. It hosted the European Athletics Championships in 1971, 1994 and 2012. It is also the home stadium of the Finland national football team.


title: Helsinki Olympic Stadium

text: The Olympic Stadium was designed by the architects Yrjö Lindegren and Toivo Jäntti. The Olympic stadium, known as an icon of functionalist style of architecture, was featured in the Architectural Digest as one of the best examples of Olympic architecture. Yrjö Lindgren later became himself an Olympic medallist when he received the gold medal for architecture at the 1948 Olympics in London.


title: Helsinki Olympic Stadium

text: Construction of the Olympic Stadium began in 1934 and it was completed in 1938, with the intent to host the 1940 Summer Olympics, which were moved from Tokyo to Helsinki before being cancelled due to World War II. It hosted the 1952 Summer Olympics over a decade later instead. The stadium was also to be the main venue for the cancelled 1943 Workers' Summer Olympiad.


title: Helsinki Olympic Stadium

text: The stadium was completely modernized in 1990–1994 and also renovated just before the 2005 World Championships in Athletics.


title: Helsinki Olympic Stadium

text: In 2006, an American TV series, "The Amazing Race 10", had one of its episodes ending at The Olympic Stadium Tower. As a task, teams had to do a face-first rappel (known as the Angel Dive) down the Helsinki Olympic Tower.


title: Helsinki Olympic Stadium

text: Since March 2007, a Eurasian eagle-owl has been spotted living in and around the stadium. On June 6, 2007, during a Euro 2008 qualifying match, the owl delayed play by ten minutes after perching on a goalpost. The owl was later christened Bubi and was named as Helsinki's Resident of the Year.


title: Helsinki Olympic Stadium

text: The 50th anniversary of the Helsinki Olympic Games hosted in the Helsinki Olympic Stadium was the main motif for one of the first Finnish euro silver commemorative coins, the 50th anniversary of the Helsinki Olympic Games commemorative coin, minted in 2002. On the reverse, a view of the Helsinki Olympic Stadium can be seen. On the right, the 500 markka commemorative coin minted in 1952 celebrating the occasion is depicted.


title: Helsinki Olympic Stadium

text: The stadium's spectator capacity was at its maximum during the 1952 Summer Olympics with over 70,000 spectator places. Nowadays the stadium has 36,251 spectator places. During concerts, depending on the size of the stage, the capacity is 45,000–50,000.


title: Helsinki Olympic Stadium

text: The tower of the stadium, a distinct landmark with a height of , a measurement of the length of the gold-medal win by Matti Järvinen in javelin throw of 1932 Summer Olympics.


title: Helsinki Olympic Stadium

text: Major renovation work at the stadium started in the spring of 2016. During renovation all the spectator stands were covered with canopies and the field area and the tracks were renewed. The stadium now also offers extended restaurant areas and more indoor sport venues. The renovation was completed and the stadium was open to the public in September 2020.


title: Helsinki Olympic Stadium

text: The projected cost of the renovation was expected to consume €197 million in 2016, €261 million in 2019 and ended up at a price of €337 million, which is €140 million (or 70 percent) more than the original projected cost. The Finnish state and the City of Helsinki are the funders of the renovation.


The Haunting in Connecticut 2: Ghosts of Georgia is a 2013 psychological horror film that serves as a spiritual successor to "The Haunting in Connecticut" by Gold Circle Films. The script was written by David Coggeshall and Tom Elkins served as director. It was released in a limited theatrical run, and through video on demand, on February 1, 2013. The story was inspired by the events surrounding the Wyrick house of Ellerslie, Georgia, which were published in the book "The Veil: Heidi Wyrick's Story".


title: The Haunting in Connecticut 2: Ghosts of Georgia

text: The film is set in 1993. Andy and Lisa Wyrick, along with their daughter Heidi, move into a rural home after receiving a deal from the bank. They are told that no one had previously lived on the land, which is why they are getting such a great deal. Shortly after moving in, Heidi begins to experience visions. After a visit from Lisa's sister Joyce, it is revealed that Heidi, along with her mother, aunt, and grandmother, was born with a veil over her face, allowing the women of the family to have visions. Joyce embraces her visions, but Lisa tries to prevent them with the help of medication to no avail as she begins to have nightmares and visions of her mother.


text: One of Heidi's visions is of a man she calls Mr. Gordy, who tells her things to prove his existence, such as money being buried in the garden, and a swing being deep in the woods. When these things turn out to be true, it is revealed that Mr. Gordy had in fact owned the house before the Wyricks. To test Heidi's knowledge, Joyce and Lisa do some research and ask Heidi to pick Mr. Gordy out of a bunch of old photos, which she does. Lisa begins to have visions of a figure coming after her and her daughter and starts to worry about the sanity of herself and that of her daughter, which leads her to tell Heidi not to speak to Mr. Gordy anymore.


text: One day, the family receives a visit from the local pastor, who tells them that their property was once part of the Underground Railroad and that a stationmaster lived on their land. He tells them of all the good that the stationmaster brought about and warns the family that they may get some visitors wishing to pay homage to the stationmaster, and asks them to be kinder than the previous owner, Mr. Gordy, was.


text: Andy comes home with a dog for Heidi named Chief, trying to alleviate some of the tension that has built up in their family since moving into the new house, but soon after Chief follows something into the woods. When Andy and Heidi go to look for him, they can hear him crying from the woods and find him trapped in a snare. Andy tells Lisa that the snares would have been perfect for a taxidermist, because they would catch and kill animals without leaving a mark. While destroying the snares to prevent Chief from getting caught again, Andy finds Heidi talking to someone who is not there. When he asks her about it, she says that Mr. Gordy says that some people are coming.


text: These people turn out to be Mama Kay and her grandson who buy a quilt from Joyce that she had found at the old station. Mama Kay tells Heidi that she is special and to be careful of what she sees, while her grandson tells Andy the true story of the stationmaster. He was primarily a taxidermist and would enlist the help of guides called conductors to help guide slaves to a meeting place. He would hold them somewhere secret, then when it was safe, he would move them to the next location. Two of the slaves he had hidden were Mama Kay's ancestors, Nell and Levi, but they were never heard from again after they stopped at the station. When the townspeople found out about his involvement, they blindfolded him, filled his abdomen with stuffing and hanged him from the tree where the swing once was that Heidi had seen.


text: Andy relays this information to Joyce and Lisa, who then relays it to Heidi, but tells her that the stationmaster was a good man and helped a lot of people. When Heidi insists that an evil exists in the woods, Lisa becomes frustrated and tells her that she cannot believe her because she cares about her and orders Heidi to get out of the bathtub. When Heidi takes too long, Lisa returns to the bathroom as the lights flicker. The stationmaster is seen standing next to Lisa as Heidi is face down in the bathtub. Lisa pulls her out and attempts to use the Heimlich maneuver to expel the water from her lungs, only for Heidi to cough up sawdust and insects. Concerned, the family takes Heidi to the hospital, where her story is questioned. Heidi seems to have no memory of what happened and tells the doctor that when she didn't get out of the tub like she was supposed to, her mom pulled her out of the tub really hard, making it even harder to believe Lisa's story. As Lisa is leaving, Heidi tells her that it is hard when people don't believe you, indicating that she knew what she was doing.


text: Later, the family asks the pastor to come out and bless the land and Heidi. During the blessing, Joyce experiences frightening visions of slaves being taken to the station by the stationmaster, along with the conductors, and she sees the bodies of her family members decomposing during the blessing. That night Heidi follows a ghost out of her house, who turns out to be Nell. She leads her out into the woods, where she disappears. Meanwhile, Lisa is having nightmares and awakens to find out that Heidi is missing, and Andy runs out into the woods to look for her.


text: Somehow, Heidi falls to the bottom of the station and begs her father not to leave her down there with "them", but she is alone. In a frantic attempt to rescue his daughter, Andy reveals a heavy slab covering the entrance, which leads him to wonder how Heidi got down there, and he realizes that is where the stationmaster hid the slaves, with Heidi revealing the "them" she was talking about were corpses that had been forgotten. When the stationmaster was murdered, there was no one to let the slaves out and they died in the station. Heidi tells her father that she thinks something else is in the station too. She tells her family that she wishes to leave the house. Joyce tells her that she released the spirits and that the bad things are gone, but Heidi insists that Mr. Gordy told her she let something bad out. When Andy takes his daughter's side, it causes a rift between him and Lisa. Lisa tells Heidi that the stationmaster was a good man, to which Heidi replies, "No, he wasn't".


text: Andy decides that the family will leave because he doesn't want Lisa filling Heidi's head with the idea that she is sick and needs to be on medication. As they are packing up to leave, the ghost of the stationmaster can be seen watching them. Joyce decides to stay and the ghosts of the slaves alert her to the stationmaster's presence. She sees him walking towards Heidi and when she attempts to warn her niece, the stationmaster turns his attention on her. Joyce coughs up a needle and begins to become sutured from the inside. Meanwhile, Lisa notices that Heidi has disappeared from the truck and she decides to check Joyce's trailer. She finds her sister strung from the ceiling and cuts the sutures just before the stationmaster is able to get them. When Lisa asks her sister where Heidi is, Joyce replies that "they know", which leads Lisa to accept her visions.


text: She follows the guidance of the conductor's ghost, which leads her to the station. There, she finds a hidden door and discovers many animals that had been stuffed by the stationmaster. It is revealed that the stationmaster had kept many slaves and stuffed them for his own keeping, including Nell, Levi, and the conductor. She finds Heidi tied to the stationmaster's table, and when she attempts to escape with her daughter, she finds the way blocked, except by going straight up through the ground. Heidi begins to climb and then is pulled up through the ground. When Lisa attempts to follow her, she is pulled back down by the stationmaster. She is confronted by the ghost, but experiences a vision of her mother who tells her to "let them in". She finally embraces her visions and finds out that the stationmaster had told Nell, Levi, and the conductor that he would be back for them, but traps them instead, leaving them to starve so that he could stuff them. Learning the truth, it allows their spirits to be freed and have their vengeance on the stationmaster. The stationmaster's death is revisited, but instead of it being the townspeople who murder him, it is the spirits of all those he had killed. This allows Lisa to escape and the stationmaster's spirit to be destroyed. It is then revealed that the person who had pulled Heidi through the ground was actually the spirit of Mr. Gordy, who was the stationmaster's descendant and was acting as a protector of the Wyrick family.


text: Two weeks later, Andy attempts to hang a tire swing for Heidi. Lisa and Joyce speculate about why Mr. Gordy hadn't wanted people on his land and come to the conclusion that he wanted his ancestor to be remembered for the good that he did and not the bad. Meanwhile, Heidi is struggling to ride her bike when it suddenly straightens up. She turns around to see Mr. Gordy and he sends her off to ride happily where she sees the spirits of Nell, Levi, and the Conductor heading off into the woods, finally free. She turns around and sees Mr. Gordy waving goodbye to her before he turns and walks away into the afterlife, satisfied that the Wyricks are safe.


text: In a text epilogue, it is revealed that the Wyricks remained in that house for another five years, Lisa's visions have not returned, and that Heidi never saw Mr. Gordy again. The final shot shows photos of the real-life Heidi and Mr. Gordy, and then the entire Wyrick family.


text: The film was given a limited release in the United States on 1 February 2013 and around the world during 2013 with a wide release in the United Kingdom on 31 October 2013.


text: The film received mostly negative reviews, though it fared slightly better than its predecessor, with a 19% approval rating based on 16 reviews on Rotten Tomatoes; Metacritic gave the film a score of 25 out of 100, indicating "generally unfavorable reviews", based on five reviews.


title: Succession to the Crown Act 2013

text: The Succession to the Crown Act 2013 (c. 20) is an Act of the Parliament of the United Kingdom that altered the laws of succession to the British throne in accordance with the 2011 Perth Agreement. The Act replaced male-preference primogeniture with absolute primogeniture for those in the line of succession born after 28 October 2011, which means the eldest child, regardless of gender, precedes any siblings. The Act also repealed the Royal Marriages Act 1772, ended disqualification of a person who married a Roman Catholic from succession, and removed the requirement for those outside the first six persons in line to the throne to seek the Sovereign's approval to marry. It came into force on 26 March 2015, at the same time as the other Commonwealth realms implemented the Perth Agreement in their own laws.


title: Succession to the Crown Act 2013

text: Under the Act of Settlement 1701, the throne of the Kingdom of England was settled on the Electress Sophia of Hanover and the "heirs of her body", this phrase being understood under English common law to imply male-preference primogeniture, meaning that brothers would precede sisters in the line of succession. This Act also prevented a "papist" (Roman Catholic) from inheriting the English throne and removed those who had married Roman Catholics from the line of succession.


title: Succession to the Crown Act 2013

text: The treaties that created the Kingdom of Great Britain in 1707 and the United Kingdom of Great Britain and Ireland in 1801 specifically applied these provisions to the new British throne. Article II of the Acts of Union 1707 stated that the "Succession of the Monarchy" is settled by the Act of Settlement 1701 and that the ban of "Papists" from inheriting the throne was to continue according to that Act. Article 2 of Acts of Union 1801 again maintained that the succession rules in place in the new United Kingdom of Great Britain and Ireland should be "continued limited and settled in the same manner".


title: Succession to the Crown Act 2013

text: Since the Acts of Union 1707, male preference primogeniture has operated twice to displace a female by a younger brother: when Princess Augusta's younger brother became King George III on the death of their grandfather King George II (1760); and when Princess Victoria's younger brother became King Edward VII on the death of their mother Queen Victoria (1901).


title: Succession to the Crown Act 2013

text: Princess Anne is the younger sister of King Charles III. Her place in the line of succession is not affected by the provisions of the Act relating to male preference in that she remains head of the line following those headed by her younger brothers. Their lines continue to precede hers under male preference because all four siblings were born before 28 October 2011.


title: Succession to the Crown Act 2013

text: In December 2011 the Statement of Friday 28 October 2011 issued at Perth was published in a House of Commons committee report. It stated that the prime ministers of the sixteen Commonwealth nations "of whom Her Majesty the Queen is Head of State" had "agreed in principle to work together towards a common approach to amending the rules on the succession to their respective Crowns", and that they would wish "unanimously to advise The Queen of their views and seek her agreement." The statement continued:


title: Succession to the Crown Act 2013

text: In a letter to the other realms' heads of government, prior to the Perth Agreement, British Prime Minister David Cameron had additionally proposed to limit the requirement to obtain the monarch's permission to marry to the first six people in line to the throne.


title: Succession to the Crown Act 2013

text: The bill was published on 13 December 2012, and after passing both Houses of Parliament it received royal assent on 25 April 2013, immediately before the prorogation of Parliament that day.


title: Succession to the Crown Act 2013

text: The purpose of the Succession to the Crown Act is to give effect in the United Kingdom to the Perth agreement. The British government announced that the Act's provisions were not intended to come into force before the appropriate domestic arrangements were in place in the other Commonwealth realms.


title: Succession to the Crown Act 2013

text: Males born after 28 October 2011 no longer precede their elder sisters in the line of succession. There has not yet been a monarch's succession affected by the new rule. The first people in the line of succession to be affected by the changes on the date they came into force were the children of Lady Davina Lewis, her son Tāne (born 2012) and her daughter Senna (born 2010), who were reversed in the order of succession, becoming 29th and 28th in line respectively. The current first affected successor in line is Princess Charlotte of Wales, who would otherwise be preceded by Prince Louis of Wales.


title: Succession to the Crown Act 2013

text: When the Act came into force in May 2013, the Duchess of Cambridge was expecting her first child, and its provisions would have had significant effect had the child been a girl, with media commentary focusing on the potential for the birth to make history. In the event it was a boy, Prince George of Wales, who was born in July that year, and upon whom the Act had no practical effect. However, it has since taken on significance for his younger siblings. Princess Charlotte of Wales was from her birth on 2 May 2015 fourth in line to the Throne, after Prince George and ahead of Prince Harry, just as she would have been had the Act not been passed. However, due to the provisions of the Act, she has retained her place in the succession ahead of her younger brother Prince Louis of Wales, who was born on 23 April 2018.


title: Succession to the Crown Act 2013

text: Marrying a Roman Catholic no longer disqualifies a person from succeeding to the Crown. The explanation published when the bill was introduced mentioned that those who had lost their places in the line of succession by marrying a Roman Catholic would regain their places, but that those "with a realistic prospect of succeeding to the Throne" would not be affected. The first person in the new line of succession to be affected by this change when it came into effect was George Windsor, Earl of St Andrews, who had married a Roman Catholic in 1988 and was restored to the line of succession in 34th place, after his father Prince Edward, Duke of Kent. The provision of the Act of Settlement prohibiting the monarch from being a Roman Catholic continues. Some have raised concerns about this portion of the act, given that the Canon Law of the Catholic Church, says that Catholics who marry baptized non-Catholics, before getting permission to marry the non-Catholic must "make a sincere promise to do all in his or her power so that all offspring are baptized and brought up in the Catholic faith". In a case where a Catholic's child was in the succession line to the throne, this would bring up clashes with the current ban on Roman Catholics reigning on the throne.


title: Succession to the Crown Act 2013

text: The Royal Marriages Act 1772 is repealed. Instead, only the first six persons in line to the throne require the Sovereign's approval to marry. For these six, marriage without the Sovereign's consent would disqualify the person and the person's descendants from succeeding to the Crown. However, the marriage would still be legally valid.


title: Succession to the Crown Act 2013

text: Marriages legally void under the Royal Marriages Act 1772 will be treated as never having been void, except for purposes relating to the succession to the Crown, provided all the following conditions are met:


title: Succession to the Crown Act 2013

text: Provisions in the Acts of Union 1707, between England and Scotland, and in the Acts of Union 1800, between Great Britain and Ireland, that involve the Crown are "subject to provisions of" the Act, several sections in the Bill of Rights 1689 and the Act of Settlement 1701 involving marriages with "papists" (Catholics) were repealed. Any references to provisions relating to "the succession to, or possession of, the Crown" also include, by reference, the provisions of this act.


title: Succession to the Crown Act 2013

text: However, the sections that ban Catholic succession were not repealed. Catholics are still officially termed as being "naturally dead and deemed to be dead" in terms of succession. This distinction was first legislated in the Bill of Rights 1689. Jacob Rees-Mogg (Con) also confirmed "the Act of Settlement deems somebody who has been a Catholic for a minute to be 'dead' in terms of the succession, and it passes over them 'as if they were dead'. It is an absolute. If at any moment in their whole life they were in communion with Rome, they are excluded from the throne, deemed to be dead." Mark Durkan (SDLP) made a comparison of this with McCarthyism, "In effect, it is the McCarthyite question: 'Are you now or have you ever been a Catholic?'”. He then went on with a summary of the proviso saying, "For anybody who has ever been a Catholic in any shape or form, that is it, they are out; they count as dead for these purposes." The ban continues. A person who has never been a Catholic but who is not Protestant is permitted to succeed if they convert to a Protestant communion, since a Protestant monarch is required by the Acts of Union 1707.


title: Succession to the Crown Act 2013

text: As the monarch's eldest son will no longer automatically be heir apparent, the Treason Act 1351 was also amended, so that encompassing the death of the monarch's eldest son is now extended to murdering the heir apparent, whatever the sex. Another amendment to the Treason Act is that, whereas it had been treason to "violate" the monarch's eldest son's wife, it is now only treason if the eldest son is also the eldest child.


title: Succession to the Crown Act 2013

text: The Regency Act 1937 was amended to require the regent to be a person who had not been disqualified from the succession by marrying without the monarch's permission under the 2013 Act.


title: Succession to the Crown Act 2013

text: None of the provisions of the act altering the law, including those which will or may affect any direct or collateral line of succession to the British throne, were to come into force until a day appointed for it by a commencement order made by the Lord President of the Council. When publishing the bill the government had announced that it was expecting to bring the provisions into force at the same time as the other realms would be bringing into force any changes to their legislation or other changes necessary for them to implement the Perth Agreement. This was done on 26 March 2015.


title: Succession to the Crown Act 2013

text: The legislation passed in the realms of Australia, Barbados, and Canada make reference to the United Kingdom legislation in different ways. The Succession to the Crown Act 2015, passed by the parliament of the Commonwealth of Australia, is expressed to be for changing "the law relating to the effect of gender and marriage on royal succession, consistently with changes made to that law in the United Kingdom, so that the Sovereign of Australia is the same person as the Sovereign of the United Kingdom". The Succession to the Throne Act, 2013, passed by the parliament of Canada, refers to the bill (not the act): "The alteration in the law touching the Succession to the Throne set out in the bill laid before the Parliament of the United Kingdom and entitled A Bill to Make succession to the Crown not depend on gender; to make provision about Royal Marriages; and for connected purposes is assented to." The parliament of Barbados' Succession to the Throne Act, 2013, uses similar wording to Canada's law: "The Parliament of Barbados acquiesces to the alteration in the law relating to the Succession to the Throne set out in the Bill laid before the Parliament of the United Kingdom and entitled A Bill to make succession to the Crown not depend on gender; to make provision about Royal Marriages; and for connected purposes."


title: Succession to the Crown Act 2013

text: On 21 January 2013, the Church of England published a briefing endorsing the bill's provisions and stating, "The use of fast-tracking procedures [for the bill] is acceptable." The same day, the "Telegraph" reported that the Church of England had written to MPs to express its official backing for the proposed changes.


title: Succession to the Crown Act 2013

text: A report on the rules of royal succession was prepared by the Political and Constitutional Reform Select Committee of the House of Commons, chaired by Graham Allen, and was published in December 2011. The report welcomed the proposals, but drew attention to "connected issues that may be raised when the proposals are debated, depending on the scope of the bill, especially the future role of the Crown in the Church of England, and the continued ineligibility of women to succeed to the majority of hereditary peerages, which remains a matter of public interest for as long as it has an impact on gender balance in the House of Lords".


title: Succession to the Crown Act 2013

text: On 9 September 2012, the British government published a response to the report, reiterating that it intended to implement the Perth Agreement but had no plans to change the laws of succession to peerages or the established status of the Church of England.


title: Succession to the Crown Act 2013

text: On 21 January 2013, the House of Lords Constitution Committee published a report opposing the Government's plan to fast-track the bill, citing the legislation's "constitutional significance" and "possible unintended consequences".


title: Succession to the Crown Act 2013

text: In response, the Government expanded the time allocated for the bill's debate in the House of Commons from one day to two days, and it decided not to fast-track the bill in the House of Lords, where the normal time limits were observed.


title: Succession to the Crown Act 2013

text: The first reading (introduction) of the bill in the House of Commons took place on 13 December 2012. Passage of an Allocation of Time motion, the second reading, and the committee stage (in the form of a Committee of the Whole House) took place on 22 January 2013. The report stage and third reading (passage) took place on 28 January 2013. The only amendment made in the House of Commons was to insert the words "from the marriage" after the word "descendants" in section 3(3), which was passed without debate.


title: Succession to the Crown Act 2013

text: The first reading of the bill in the House of Lords took place on 29 January 2013. The bill passed second reading on 14 February 2013 and was reviewed by committee on 28 February 2013. The report stage was on 13 March 2013. The bill was passed at the third reading on 22 April. No amendments were made to the bill in the House of Lords, and it received the Royal Assent on 25 April 2013.


title: Succession to the Crown Act 2013

text: Consents for marriages under the Act appear in the Privy Council Orders. The first person in line of succession to receive consent under the new law was Prince Harry.


title: France (film)

text: France is a 2021 comedy-drama film written and directed by Bruno Dumont. It stars Léa Seydoux, Blanche Gardin, Benjamin Biolay, Emanuele Arioli, Juliane Köhler, Gaëtan Amiel, Jewad Zemmar and Marc Bettinelli.


title: France (film)

text: The film follows the life of a star television journalist caught in a spiral of events that will lead to her downfall. Between drama and comedy, "France" seeks to compare the intimate and public crisis of a young woman with a portrait of contemporary France. The film had its world premiere at the Cannes Film Festival on 15 July 2021. It was released in France on 25 August 2021 by ARP Selection.


title: France (film)

text: The film is intended in particular to be a satire of the treatment of information by television channels. France de Meurs is a star journalist at a private French television station. Her fame, her way of conceiving reports and programmes, as well as a chain of personal events, will cause a total questioning of her career in media and turn her life upside down, in addition to her struggles with panic attacks and anxiety.


title: France (film)

text: In May 2019, it was announced Léa Seydoux, Blanche Gardin and Benoît Magimel had joined the cast of the film, with Bruno Dumont directing from a screenplay he wrote. In June 2020, the film was re-titled from "On a Half Clear Morning" to "France".


title: France (film)

text: The film had its world premiere at the Cannes Film Festival on 15 July 2021. It was released in France on 25 August 2021 by ARP Selection.


title: Murder of Anthony Walker

text: Anthony Delano Walker (21 February 1987 – 30 July 2005) was a Black British student of Jamaican descent who was murdered with an ice axe by Michael Barton (brother of footballer Joey Barton) and Barton's cousin Paul Taylor, in an unprovoked racist attack on the night of 29 July 2005 in Huyton, Merseyside. Walker was eighteen years old and was in his second year of A-levels. He lived with his parents, Gee Walker and Steve Walker, his two sisters and one brother.


title: Murder of Anthony Walker

text: The Walker family were one of the first black families to live in Huyton, and the children experienced racial name-calling at both primary and secondary school. Both Walker and Taylor attended Knowsley Hey High School.


title: Murder of Anthony Walker

text: Taylor and Barton had a reputation for racially abusing others. Taylor had prior convictions for battery, and burglary, and at the time of the crime was on early release from a young offenders' centre.


title: Murder of Anthony Walker

text: Anthony Walker spent the evening of 29 July 2005 at home with his girlfriend, Louise Thompson, babysitting his nephew. At 11 p.m., the couple left the house and walked to the bus stop along with Walker's cousin Marcus Binns. There, they encountered Michael Barton, aged 17, who threatened to stab Walker and Binns. As Walker, Thompson and Binns walked to another bus stop, near McGoldrick Park, Barton and his friend Paul Taylor, aged 20, followed them in a car and drove to the park, ambushing them when they reached it. Binns and Thompson managed to escape and ran away to get help, while Walker was fatally wounded when Taylor struck him in the head with an ice axe, which lodged in his skull, causing brain death. He was taken to Whiston Hospital and then to the Walton Centre, where he died at 5:25 a.m.


title: Murder of Anthony Walker

text: By the next morning, Barton and Taylor had fled to Amsterdam. When police named them as suspects, Barton's brother, footballer Joey Barton, appealed for them to return to the UK and turn themselves in. They flew back to Liverpool on 3 August and were arrested and charged with Walker's murder.


title: Murder of Anthony Walker

text: The trial took place between November and December 2005, and on 1 December, Taylor and Barton were convicted of the murder. Passing life sentences, with minimum terms of 23 years and eight months for Taylor, who had admitted the murder just before the trial, and 17 years and eight months for Barton, Lord Justice Leveson said that the cousins had perpetrated a "terrifying ambush" and a "racist attack of a type poisonous to any civilised society". Barton's sentence was reduced by eight months to 17 years in 2016, in recognition of improvements in his attitude and behaviour.


title: Murder of Anthony Walker

text: In April 2006, it was reported that Barton had been attacked by fellow inmates at Moorland Closed Prison near Doncaster, South Yorkshire.


title: Murder of Anthony Walker

text: Three other people were later found guilty of helping Barton and Taylor flee to the Netherlands before their eventual arrest. On 10 May 2006, Robert Williams was convicted of providing money and booking a hotel room for the pair. He was sentenced to two years and four months. Paul Morson was sentenced to 11 months in prison for providing a getaway car. Tracy Garner admitted assisting an offender and received an 11-month suspended sentence and 50 hours of community service.


title: Murder of Anthony Walker

text: Although they drew frequent comparisons, many denied that there were similarities between Walker's killing and that of Stephen Lawrence in 1993. One such critic was Labour MP Edward O'Hara, who stated that, although there was a "certain surface comparison", Walker's killing was "random, exceptional and representative of absolutely nothing".


title: Murder of Anthony Walker

text: Walker's mother explained her attitude towards her son's killers, saying "I have to forgive them. I can't feel anger and hatred, because that is what killed my son". However, Walker's girlfriend Louise, who was present on the night of his murder, said she never would forgive them adding, "I hate them for what they have done. Anthony and I shared something special. Now he has been taken away from me by those two evil young men. I still feel that he (Anthony Walker) is around. Yesterday, I sent Anthony a text and just told him he (Barton) had been found guilty. It seemed the natural thing to do."


title: Murder of Anthony Walker

text: Walker's murder and the subsequent trial of the perpetrators received a large amount of media coverage in the UK, with a media pack congregating at John Lennon Airport awaiting the return of the accused. His funeral was broadcast live on television and the BBC ran a special "Real Story" programme about the crime which was broadcast on 2 December 2005.


title: Murder of Anthony Walker

text: In 2020, Jimmy McGovern dramatised Walker's case in the TV film "Anthony", with Toheeb Jimoh in the title role, looking at what Walker might have achieved had he lived. The film was made with the support of Anthony's mother Gee Walker.


title: Murder of Anthony Walker

text: On 2 April 2008, the Crown Prosecution Service announced a legal scholarship in Walker's memory. The scheme offers one place in CPS Merseyside to a trainee solicitor who wants to become a fully fledged solicitor or barrister. It is open to any black or ethnic minority person who has secured or intends to apply for a place to study the Legal Practice Course or Bar Professional Training Course full-time.


title: Murder of Anthony Walker

text: The Anthony Walker Foundation was created in 2006 and "works to tackle racism, hate crime and discrimination by providing educational opportunities, victim support services and by promoting equity and inclusion for all". In the year of its creation, the foundation held an "Anthony Walker Festival". In November 2021, Anthony's mother, Gee Walker, received a Pride of Britain Award for her work with the foundation.


title: David Gold (businessman)

text: David Gold (born 9 September 1936) is a British businessman. He was the chairman of Birmingham City Football Club until 2009. Since 2010, he has been the joint chairman of West Ham United.


title: David Gold (businessman)

text: Gold was born in Stepney and brought up in East London at 442 Green Street near to West Ham's Boleyn Ground. He played youth team football for West Ham and was offered forms to sign as an apprentice professional for the first team, which his father refused to counter sign. His father, Godfrey, was an East End criminal, known locally as 'Goldy', who spent time in prison during Gold's early years. His father was Jewish, whereas his mother was a Christian.


title: David Gold (businessman)

text: Gold owns Gold Group International (GGI), the parent company of the retailer Ann Summers and lingerie chain Knickerbox. GGI was jointly owned by Gold and his brother Ralph, until he bought out Ralph's share in 2008.


title: David Gold (businessman)

text: He co-owned (with brother Ralph) adult magazine company Gold Star Publications (GSP), including printing and distribution businesses, and a stable of titles including "Rustler" and "Raider". He and his brother sold their interests in November 2006. In 2007, the brothers also sold their share in Sport Newspapers, following falling sales and profits.


title: David Gold (businessman)

text: Gold is the former chairman of Birmingham City F.C. In 2007 the Gold brothers were believed to be in the process of selling their share in Birmingham City which followed Birmingham's return from relegation and lower than expected profits. After the club was relegated once again to the Championship in May 2008, Gold was quoted as saying he was considering stepping down as joint head of the board of Birmingham City. He sold his Birmingham City shares in 2009.


title: David Gold (businessman)

text: In May 2005, Gold bought the second FA Cup trophy at auction for £488,620, saying he wanted to prevent it being bought by overseas buyers.


title: David Gold (businessman)

text: In January 2010, Gold and David Sullivan acquired a 50 per cent share of West Ham United giving them overall operational and commercial control of the club. They were appointed joint chairmen. They increased their share of the club to 30% each in May 2010 at a cost of £8 million. His time as chairman of West Ham has been conspicuous due to several incidents. In August 2010 his Rolls-Royce Phantom car was attacked by Aston Villa fans outside a pub near Villa Park after West Ham's 3–0 defeat. The car sustained £8,500 worth of damage. He described the incident as "the most frightening experience of my football life".


title: David Gold (businessman)

text: In November 2010 Gold criticised Birmingham City's new owners for reneging on their promise to keep him on as chairman following the sale of the club. Birmingham City and their acting chairman, Peter Pannu, responded by banning Gold from their ground St Andrew's for Birmingham City's game against West Ham on 6 November.


title: David Gold (businessman)

text: After the campaign against Malcolm Glazer's increase in the debt of Manchester United and Portsmouth going into administration in 2010, Gold has advocated regulating football clubs' debts. He feels it is "cheating" for a team to take on debts which they could never pay off without external assistance and that he "fears for the league".


title: David Gold (businessman)

text: In 1957, Gold married Beryl Hunt. They divorced in 1972 after Gold found her cheating on him with his best friend in his swimming pool, on the same day he caught his father stealing his shares. Hunt died in 2003. They had two children:


title: David Gold (businessman)

text: In 2005, Gold wrote his autobiography "Pure Gold" with co-writer Bob Harris. This dwells on his early childhood poverty, ascent in business and involvement with Birmingham City.


title: David Gold (businessman)

text: Following West Ham's move from the Boleyn Ground to the London Stadium in 2016, Gold was subjected to protests from groups of West Ham supporters who were unhappy with the move and who accused Gold of having taken money from the club and of being a "liar".


title: Uzumaki (film)

text: The film was backed by the company Omega Micott, who released it in Japan on a double bill with "", another film based on a manga by Ito. Simultaneously, "Uzumaki" received a limited release in the American city of San Francisco. It received mixed reviews from critics.


title: Uzumaki (film)

text: High school student Kirie Goshima's first glimpse that something is awry in the small town of Kurouzu-cho comes when her boyfriend Shuichi Saito's father begins to film the corkscrew patterns on a snail; he is also in the process of making a video scrap book filled with the images of anything that has a spiral or vortex shape to it. His unusual obsession causes him to abandon his responsibilities at work; he proclaims that a spiral is the highest form of art, and frantically creates whirlpools in his miso soup when he runs out of spiral-patterned "kamaboko". He then decides to film himself crawling into a washing machine, where he dies.


title: Uzumaki (film)

text: It is not long before the entire town is infected by the otherworldly spirals. Tamura, a reporter, is intrigued by Shuichi's father's suicide and becomes obsessed with the case. Meanwhile, Shuichi's mother, who has been in hospital since her husband's death, has developed a severe phobia of spirals. She cuts off her hair and fingertips due to their spiral-like shapes, and Shuichi tells the hospital staff to eliminate anything spiral-shaped so his mother may not encounter them. One night, after a millipede tries to crawl into her ear while she is asleep, Shuichi's mother hallucinates her husband telling her that "there's another vortex in the deepest part of your ear", and is driven to suicide.


title: Uzumaki (film)

text: At Kirie's high school, a student named Katayama begins to walk at a snail's pace, dripping in a slimy substance and only attending school on rainy days. He and other members of the student body gradually begin to sprout shells, drink water in copious amounts, and crawl on the walls of the school. Kirie's classmate, Sekino, begins to grow her hair in exaggerated curls, taking over her mind and the minds of other female students. Whirl-like clouds appear in the sky, and during funerals, they are accompanied by smoky, ghost-like faces of victims who perished in spiral-related ways.


title: Uzumaki (film)

text: Eventually, the entire town succumbs to the curse of the spiral—Kirie's father takes a drill to his eye after obsessively creating spiral shaped ceramics; a news crew reporting on the phenomenon lose themselves in a tunnel, only to be later found as humanoid yet snail-like corpses; and Sekino's snake-like curls grow to an abnormal height, wrapping around a telephone pole and cables electrocuting herself. A boy who wants Kirie to be his girlfriend throws himself in front of Inspector Tamura's car and is twisted around the axle; the car collides with a pole, causing Tamura's head to hit the windshield, leaving a spiral-shaped crack. When Kirie and Shuichi decide to search for Kirie's father, Shuichi's body twists into a spiral-like contortion. He crawls towards Kirie, asking her to "become a spiral too".


title: Uzumaki (film)

text: "Uzumaki" is based on the manga "Uzumaki", written and illustrated by Junji Ito. Ito had stated that for most of his stories, he starts with a visual image and builds a story around the picture. For "Uzumaki", he had a different inspiration of wanting to make a film about people who lived in a traditional Japanese row-house and seeing what happened. When drawing the row-houses, he found himself drawing a very long house that coiled into a spiral to fit on his page.


title: Uzumaki (film)

text: The film was the debut feature for director Akihiro Higuchi, under his alias of Higuchinsky. While filming the television series "Eko Eko Azarak", director Higuchinsky met Kengo Kaji who he proposed the idea of making a film to. Higuchinsky stated that he originally wanted to make a film like "Star Wars" but realized that "because I'm Japanese, I should do something different."


title: Uzumaki (film)

text: Higuchinsky had been reading a manga magazine compilation which contained Ito's "Uzumaki". Higuchinsky thought the manga was brilliant and asked Kengo Kaji to adapt the film, finding out that the manga was already in the process of being made into a film and that producers were looking for a director. Higuchinsky described the lure of "Uzumaki" using the Japanese word "kikai", which translates to "strange and mysterious things (or people)", and that "the allure of "Uzumaki" is not that the uzumaki itself is scary but rather the changes in the people caught up in it. " The original production of the film was going to be an independent production and would be part of an anthology film, but during production, Toei Animation decided to have it become a bigger film. The film was backed by Toyoyuki Yokohama's Omega Project, a company that married Japanese and foreign funding to make J-horror films for an international market. The company had previously had success with the 1999 film "Audition".


title: Uzumaki (film)

text: Higuchinsky desired to be faithful to the manga as possible. At the time, the manga had not been completed yet.


title: Uzumaki (film)

text: To help his crew express a Japanese style in the film, he had his staff watch "Akuma no temari uta". The film was primarily shot in Ueda, Nagano Prefecture, with a few locations in Tokyo. Higuchinsky said the film was shot in about two weeks.


title: Uzumaki (film)

text: "Uzumaki" was released in Japan on 11 February 2000. It was released as the first half of a double bill with "", a film based on the manga "Tomie", also by Ito. The film was released concurrently in the United States as it was in Japan with a limited run in San Francisco. Omega's vice-president Akiko Funatsu stated that San Francisco was chosen due to "all the internet activity there".


title: Uzumaki (film)

text: On review aggregator website Rotten Tomatoes, the film has an approval rating of 56% based on 25 reviews, with an average rating of 6.09/10. The site's critics consensus reads, ""Uzumaki" uses its creepy, David Lynch-inspired atmospherics to effectively build a sense of dread, but ultimately fails to do anything with it." On Metacritic, the film has a score of 62 out of 100 based on nine critics, indicating "generally favorable reviews".


title: Uzumaki (film)

text: In his review of the film for "The New York Times", critic Elvis Mitchell noted the way the film develops mood, finding it part of the cycle of Japanese films like Kiyoshi Kurosawa's "Cure" and Hideo Nakata's "Ring" as "vivid, state-of-the-art scare films that move so swiftly that psychological underpinnings are a luxury". Mitchell concluded that in the film that "things really get weird, though not particularly scary", calling the film "ultimately disappointing". "Variety"s Dennis Harvey described the film as "intriguing, if ultimately unsatisfying", and criticized a perceived lack of atmosphere between set pieces, along with its "typically bland, schoolgirlish heroine." Kim Morgan of "The Oregonian" described the film as "beautiful, cold, oddly colorful and just plain otherworldly"; she wrote that it contains "many creatively terrifying and effectively gross sequences that stand on their own beautifully", but lamented that it "doesn't flow into a consistent building of terror".


title: Uzumaki (film)

text: Ross Williams of Film Threat praised the film's sound design and "cheesy, yet at the same time impressive and effective" special effects, writing: "While not as effectively creepy as "The Ring", ["Uzumaki"] undoubtedly deserves to be watched". Scott Tobias of "The A.V. Club" noted the style of the film, opining that kinetic shooting style doesn't pause for anything; like a lot of music-video and commercial directors, his achievement is better considered shot-by-shot than as a whole." AllMovie's Josh Ralske gave the film a score of three-and-a-half stars out of five, calling it "visually imaginative and engagingly offbeat horror film, but its willful goofiness and unresolved story line doesn't offer much in the way of psychological resonance."


title: Uzumaki (film)

text: Higuchinsky stated that, since the film's release, he has received fan mail from Europe, which made him particularly happy as it was his "dream to use film as a way to overcome national borders and have my movies watched by people all over the world. I think that these fans focus not on the story but on the simple images, they sense something through the visuals."


title: Domicile (law)

text: Domicile is relevant to an individual's "personal law," which includes the law that governs a person's status and their property. It is independent of a person's nationality. Although a domicile may change from time to time, a person has only one domicile, or residence, at any point in their life, no matter what their circumstances. Domicile is distinct from habitual residence, where there is less focus on future intent.


title: Domicile (law)

text: As domicile is one of the connecting factors ordinarily used in common law legal systems, a person can never be left without a domicile and a domicile is acquired by everyone at birth. Generally domicile can be divided into domicile of origin, domicile of choice, and domicile by operation of law (also known as domicile of dependency). When determining the domicile of an individual, a court applies its own law and understanding of what domicile is.


title: Domicile (law)

text: In some common-law countries, such as Australia and New Zealand, the concept of domicile has been subject to statutory reform. Further, under Canada’s "Divorce Act", domicile has been replaced as the basis for which a court in a province has jurisdiction to hear and determine a divorce proceeding. Instead, "A court in a province has jurisdiction to hear and determine a divorce proceeding if either spouse has been habitually resident in the province for at least one year immediately preceding the commencement of the proceeding". Although domicile was traditionally known as the most appropriate connecting factor to establish an individual’s personal law, its significance has declined over the years in common law systems.


title: Domicile (law)

text: In early societies, there was little mobility but, as travel from one state to another developed, problems emerged: what should happen if different forms of marriage exist, if children became adults at different ages, etc.? One answer is that people must be given a connection to a legal jurisdiction, like a passport, that they carry with them wherever they go.


title: Domicile (law)

text: Domicile is governed by "lex domicilii", as opposed to "lex patriae" which depends upon nationality, which is the relationship between an individual and a country. Where the state and the country are co-extensive, the two may be the same. However:


title: Domicile (law)

text: Domicile is distinct from habitual residence where there is much less focus on future intent. Domicile is being supplanted by habitual residence in international conventions dealing with conflict of laws and other private law matters.


title: Domicile (law)

text: Domicile of origin is established by law at birth to every individual. It refers to the domicile of the person's parent, and is hard for the person to lose. This means that it is not necessarily established based on where an individual was born or where their parents live. An example of domicile of origin was explained in "Udny v" "Udny", where Udny’s domicile of origin at birth was that of Scotland, even though he was born and lived in Tuscany and his father lived in England. The court made this determination based on the fact that Udny’s father’s domicile of origin was that of Scotland. This means that even if a person leaves his or her country of origin with no intention to return to it, the person will still be domiciled there until they obtain a new domicile of choice.


title: Domicile (law)

text: However, a child without parents will have a domicile of the place of which they were found. Further, a minor’s domicile of origin will be based on the particular common-law country and its rules (see Domicile of Dependency (Minors) below).


title: Domicile (law)

text: When a person is legally allowed to change their domicile of origin, they can acquire a domicile of choice. However, until an individual obtains a new domicile of choice, their domicile of origin remains. Domicile of choice can be achieved by intention and residence. This means that if an individual is living in a country and leaves it with the intention to return, then they will not have a domicile in the country they went to; instead, their domicile or origin will remain. As stated in the "Foote v Foote" case, a domicile of choice can be lost or abandoned if certain factors are met.


title: Domicile (law)

text: At common law, the domicile attributed to a child at birth depends on the domicile of the relevant parent.  In Canada, the domicile of children generally depends and changes with the domicile of the parent(s) with whom the child habitually resides. There are certain Acts within Canadian provinces for example to help determine what the domicile of a minor is, for example, section 67 of the "Family Law Act" of Ontario.


title: Domicile (law)

text: (a) if the minor habitually resides with both parents and the parents have a common domicile, that domicile;


title: Domicile (law)

text: (c) if the minor resides with another person who has lawful custody of him or her, that person’s domicile; or


title: Domicile (law)

text: (d) if the minor’s domicile cannot be determined under clause (a), (b) or (c), the jurisdiction with which the minor has the closest connection."


title: Domicile (law)

text: However, depending on the country, the common-law approach might remain in place. For example, in England, the domicile of origin of a child is determined at birth by the domicile of the father if the child is legitimate or by the domicile of the mother if the child is illegitimate.


title: Domicile (law)

text: At common law, a married woman suffered a legal incapacity to acquire her own domicile and thus retained the domicile of her husband. In Canada, some provinces, such as Ontario, Manitoba, and Prince Edward Island, British Columbia, domicile of dependency has been abolished.


title: Domicile (law)

text: "59(1) For all purposes of the law of Prince Edward Island, a married person has a legal personality that is independent, separate and distinct from that of his or her spouse"


title: Domicile (law)

text: Even in the absence of statute, it is unlikely that Canadian courts would now refuse to recognize the capacity of married women to establish their own domicile. In other common-law countries, such as Ireland, the Supreme Court has held that this concept is inconsistent with the country's Constitution. Further, the United Kingdom, New Zealand, and Australia have abolished this concept.


title: Domicile (law)

text: It is generally accepted that a person who becomes mentally incapacitated in adult life is no longer capable of forming the intent to acquire a domicile of choice and retains whichever domicile they held prior to becoming incapable. If an individual is born mentally incapable at birth or becomes so before reaching the age of majority, their domicile of dependency may continue to depend on the change with their parents, even after they reach the age of majority. There is also a "recommendation of the English and Scottish Law Commissions under which an adult who lacks mental capacity to acquire a domicile would be considered domiciled in the country with which he or she is for the time being most closely connected."


title: Domicile (law)

text: There is tension between "domicile of origin" and "domicile of choice" which arises out of the fact that the latter can only be acquired through fulfilling both:


title: Domicile (law)

text: The ability to settle permanently has been held to arise only when one can become a permanent resident of the jurisdiction for immigration purposes. For example, suppose that A came from England to Canada on a visa to work for an employer in Ontario. While there, their son B is born. A likes Canada enough to have their status changed to that of landed immigrant. When B comes of age, they decide to leave Ontario for good, but dies before settling permanently elsewhere. B's domicile of origin is England, because of A's initial inability to settle permanently in Ontario. When A obtains permission to land, Ontario becomes their domicile of choice, and B (provided they are still a minor) automatically acquires it as a domicile of dependency. When B attains the age of majority, Ontario becomes their domicile of choice until they decide to leave for good, at which time it reverts to the domicile of origin. Their new domicile of choice would only occur once they had been able to settle permanently in a new jurisdiction.


title: Domicile (law)

text: However, it is more difficult to abandon a domicile of choice than to acquire it. In the case of abandonment, both the above conditions must be fulfilled simultaneously as they are interrelated, whereas they are discrete in the latter case of acquisition.


title: Domicile (law)

text: Certain anomalous jurisprudence occurred where persons lived abroad in cases relating to extraterritorial jurisdiction. The East India Company was declared to be equivalent to a foreign government, and persons engaged in service to it for an indefinite period were deemed to have acquired Anglo-Indian domicile. Persons in the service of the Crown, as well as independent traders, could not acquire this status. As a consequence of the Indian Mutiny, the Company ceased to function as a government upon the passage of the Government of India Act 1858, and such domicile was not capable of being acquired thereafter.


title: Domicile (law)

text: Unsuccessful attempts were made to adapt that case law to other circumstances. In 1844, Stephen Lushington of the Consistory Court observed in "dicta" that, in the case of the Ottoman Empire, "every presumption is against the intention of British Christian subjects voluntarily becoming domiciled in the dominions of the Porte." Similar statements were expressed by the Court of Chancery in 1883 in rejecting the concept of an Anglo-Chinese domicile, where Chitty J of the Court of Chancery stated that "There is no authority that I am aware of in English law that an individual can become domiciled as a member of a community which is not the community possessing the supreme or sovereign territorial power." This was later endorsed by Judicial Committee of the Privy Council in 1888, in holding that "residence in a foreign country, without subjection to its municipal laws and customs, is therefore ineffectual to create a new domicile."


title: Domicile (law)

text: The reasoning behind such decisions was never satisfactorily explained, and the House of Lords later held in 1918 that these rulings built on "dicta" were wrongly decided and were thus swept aside. In holding that domicile in a foreign State could be properly acquired in such circumstances, Lord Finlay LC declared:


title: Domicile (law)

text: The rules governing civil domicile have on occasion been confused with those governing commercial domicile that appear in public international law which come into play in time of war, with emphasis on the area of prize law, where a merchant's status as an enemy or neutral come to be determined in the courts of a belligerent state. The two sets of rules are fundamentally different. The basic principles that apply are:


title: Domicile (law)

text: The rules determining domicile in common law jurisdictions are based on case law. Most jurisdictions have altered some aspects of the common-law rules by statute, the details of which vary from one jurisdiction to another. The general framework of the common-law rules has however survived in most jurisdictions and is in outline as follows:


title: Domicile (law)

text: Canada is a bijural country, but the common-law provinces follow the rules of domicile unless there is statutory authority to state otherwise. This means that within Canada a person has a domicile of origin which can be displaced by a domicile of choice. To obtain a domicile of choice two factors have to be met, "the acquisition of residence in fact in a new place and the intention of permanently settling there ... in the sense of making that place [one's] principal residence indefinitely".


title: Domicile (law)

text: An individual who successfully obtains a domicile of choice they can still abandon it. A person abandons a domicile of choice in a country, “by ceasing to intend to reside there permanently or indefinitely, and not otherwise.” Loss of domicile “requires an intention to cease to reside in a place coupled with acts that end one's residence”.


title: Domicile (law)

text: Overall, the concept of domicile and its importance has declined over the years, in relation to a connecting factor for choice of law, as a basis of jurisdiction, and as a basis for recognizing foreign divorces. However, this concept and the tests explained were discussed in an Alberta case, "Foote v Foote Estate", below.


title: Domicile (law)

text: The late Eldon Douglas Foote lived in Alberta for the first 43 years of his life and in 1970 he purchased property in Norfolk Island, and built a residence. He and his second wife acquired permanent residence status in Norfolk Island in 1977. In 1981 they divorced, and he then married Anne, an Australian citizen, in 1984, who was granted permanent resident status in Norfolk Island in 1966. In 1999, the Footes purchased an unfinished condominium property in Victoria, British Columbia, and construction was complete in 2001. They then spent three summers there. Around the same time, they made plans to sell their residence on Norfolk Island, but it was not advertised for sale. In 2004 Mr. Foote died.


title: Domicile (law)

text: The Alberta Court of Appeal agreed with the trial judge that any plans for Mr. Foote to leave Norfolk Island to take up residence in Victoria and live there indefinitely were undeveloped and the intention was ambiguous. Thus, the court upheld the decision and stated that evidence supported that Mr. Foote’s domicile changed from Alberta to Norfolk Island in 1972 and that he had not acquired a new domicile of choice in British Columbia or Alberta. Nor did he abandon Norfolk and not adopt a new domicile, which would revert his domicile to Alberta. His domicile at his death was in Norfolk Island.


title: Domicile (law)

text: At common law, if a domicile of choice is abandoned by an individual and they do not acquire a new domicile of choice, their domicile of origin revives, so that they are never left without a domicile. However, this means that a person can be linked to the laws of a particular country even if they have terminated their connection with it a long time ago.


title: Domicile (law)

text: Manitoba’s The Domicile and Habitual Residence Act (Act) has repealed the common law concept of domicile. An important aspect of the repeal includes abolishing the doctrine of revival and the rule where a woman's domicile was that of her husband, which can be found under section 3 of the Act.


title: Domicile (law)

text: As noted above, instead of following this doctrine, s 3 of The Domicile and Habitual Residence Act (which is produced below) states that this doctrine is no longer law in the province of Manitoba.


title: Domicile (law)

text: "3  The common law rules respecting domicile, including, without limiting the generality of the foregoing,


title: Domicile (law)

text: (a) the rule known as the revival of domicile of origin whereby the domicile of origin of a person revives upon the abandonment of a domicile of choice; and


title: Domicile (law)

text: The Act has other important provisions to aid in determining one's domicile too, for example section 10.