Milk and bone fracture - 1925 Words

Milk and bone fracture (Case Study Sample) Content: Case study Name: Instructor: Course: Date: Case study Introduction Milk is not just the usual drink; it has become a cultural norm in most parts of the world which goes back to thousands of years. Currently the myths and misconception of milk is still loud and clear. In 2001, the average American child consumed 104 quarts of cow's milk. Due to the presence of calcium and phosphorous in milk, the intake of milk has been associated with improved bone health but contrary to this research has proved that this is just a myth and that the opposite is true. Milk is a rich food that is composed of all nutrients and micronutrients needed by the body. Milk comes in various forms such as whole milk, skimmed milk, cheese yoghurt, salami and so on. Skim milk in particular contains little or no fatÂÂ  as compared to whole milk. As a result it is usually recommended for individuals who want to lose weight and maintain a healthy body. Generally skim milk is less healthy than whole milk since it does not contain milk fat. It lacks fat soluble vitamins such as v itamin A and K. Apart of milk fat can be removed from whole milk to make semi-skim milk. Milk is composed of several minerals such as phosphorus. Skim milk is particularly a good source of phosphorus. Phosphorus is an essential mineral that accounts for up to 1 percent of the total body weight of a human being. This paper is focused on bringing out the relationship of milk and bone fracture. There those who strongly belief that increased intake of calcium in the form of the currently recommended three glasses of milk per day helps in preventing osteoporosis, which is defined as the weakening of bones due to low bone mass. Osteoporosis causes more than 1.5 million fractures of which 300,000 are broken hips. On the other hand there are those who belief that consuming a lot of milk and other dairy products will have little effect on the rate of fractures but may contribute to problems such as heart disease or prostate cancer. It is vital to have an understanding of the function of calcium in the body so as to help establish whether milk intake has any significant effect on bone fracture. Calcium Calcium is one of the trace elements needed by the body to perform the following functions: transmission of impulse in the nervous system; growth, development and maintenance of strong healthy bones and teeth, blood clotting mechanism, and the regulation of the heart's rhythm. Ninety-nine percent of the calcium in the human body is stored in the bones and teeth. The remaining 1 percent is found in the blood and other tissues. There are two ways in which the body gets calcium. One way is through taking dietary supplements that are rich in calcium. Rich sources of calcium include dairy products, green vegetables and dried beans. Dairy products contain the largest concentration of calcium per serving and have a high absorption rate in the body (Harvard School of Public Health). Calcium supplements are usually spiked with vitamin D so as to derive more health benefits. The second way in which the body gets calcium is from the bone reserves. When the calcium level in the blood goes down below the required amount, calcium in the bone is pulled out to restore the calcium level in the blood. Statement of the problem Consumption of milk as been linked to improved bone health for a long time making it one the most consumed product in the world. Milk contains calcium which is a major component of the bone mass. Contrary to this popular belief studies have shown that intake of milk in adults has no significant effect on the health status of the bone. In fact some studies have suggested that bone intake actually depletes the much needed calcium in the body thereby making it weak and prone to fracture. This paper aims at establishing facts relating to milk consumption and bone health by engaging people of different age groups in the research. Hypothesis Null hypothesis: Milk consumption has no significant effect on reducing bone fractures on people of all age groups. Alternate hypothesis: Consumption of milk has a significant effect on the reduction of bone fractures on people of all age group. Literature review Milk is associated with the depletion of calcium from bones The myth about health benefits of milk has spread all over the world. This misconception is based on the belief that milk is a protein and calcium-rich drink making it essential for supporting good overall health and bone health in particular at any age. The confusion arising from the health benefit of milk stems from the fact that it contains calcium. A cup of milk contains about 300 mg of calcium. Several scientific studies have shown an assortment of detrimental health effects directly linked to milk consumption. These scientific studies have shown a surprising fact contrary to the conventional belief relating to milk and bone health. Studies have shown that the intake of milk actually reduces the absorption of calcium in the bone. People rarely absorb calcium present in the cow's milk and it is even worse for pasteurized milk. This is a great irony since the studies further shows that it actually increases the loss of calcium in the bones. Animal proteins contain the acidic group which makes the body pH acidic as a result biological reaction is triggered. Calcium is one of the best neutralizing agents of acidity in the body. Calcium is stored in the bone marrow. What actually happens when a person takes milk is that calcium is released from the bone reserves so as to neutralize the acidic effect brought about by milk protein. Therefore the calcium that body needs for maintaining strong healthy bone and the general good health status of the body is used to neutralize acidity. Once calcium is removed from the bones, it is excreted from the body as urine. Therefore the net result of milk intake is deficit of calcium in the body. Statistics has proved this right since countries with the lowest consumption of dairy products also have the lowest fracture incidence in their population. Despite all these facts about the milk and health the majority of mainstream health practitioners ignore these proven facts. Most doctors usually recommend that increased intake of milk in case of osteoporosis (Burckhardt, 2007). The cow's milk is specifically tailored for calves. It is the best source of food for calves. Calves usually have an average weight of about 1000 pounds at birth but they weigh approximately eight times more at the time of weaning. After weaning they never attempt to take milk again which also applies to all the other mammalian species. This is a lesson that humans need to learn and stop their obsession with milk. Each mammalian species have their own type of m ilk that is specifically tailored to meet their needs. The milk of a cow particularly contains about thrice the amount of protein present in human milk which creates metabolic disturbances in humans that have detrimental bone health consequences. The mother's milk is the best source of nutrients for the human body but the same cannot be said of the cow's milk since its composition is different from humans (London, 2011). Minerals in Milk Milk is composed of several minerals such as calcium, phosphorus, magnesium, potassium, selenium and zinc. These minerals occur in the form of salts in varying proportion in milk as follows; approximately 67% calcium, 44% phosphate and 35% magnesium salts. These salts are bound within the casein micelle and the remainders are soluble in the serum phase. The fact that calcium and phosphate are associated as salts bound with the protein does not affect the nutritional availability of either calcium or phosphate. Several studies have shown that calcium supplementation can retard bone loss among adult women. However, inconsistent results from prospective studies and interventions trials '4 have not provided strong support for a positive association between adult calcium intake and osteoporotic fractures. The fragility...

Hunter and New England Local Health District - Free Essay Example

Hunter and New England Local Health District v McKenna [2014] HCA 44 Introduction The case of Hunter and New England Local Health District v McKenna[1] concerned the primary issue of whether a common law duty of care owed to third parties by health authorities and their employees were consistent with the appellantsà ¢Ã¢â€š ¬Ã¢â€ž ¢ statutory obligations in relation to detaining and discharging mentally ill persons[2], under the Mental Health Act 1990 (NSW) (MHA).[3] The High Court of Australia unanimously held in favour of the appellants. An objective of the MHA, however, was the à ¢Ã¢â€š ¬Ã‹Å"controlà ¢Ã¢â€š ¬Ã¢â€ž ¢ of mentally ill patients.[4] On this basis, the decision of the High Court is questionable, as the Court failed to assess a least restrictive environment enabling care and treatment against the necessity for à ¢Ã¢â€š ¬Ã‹Å"controlà ¢Ã¢â€š ¬Ã¢â€ž ¢. Such a need for control was required in these circumstances, and accordingly gave rise to a duty of care which was breached through the discharge of the patient. Facts Mr Pettigrove, who suffered from a history of mental illness, was involuntarily admitted to, and detained in hospital, upon his friend, Mr Rose, being concerned about the mental state of Mr Pettigrove. Following an assessment by a psychiatrist, he was discharged into the custody of Mr Rose to enable them to travel to Victoria where Mr Pettigroveà ¢Ã¢â€š ¬Ã¢â€ž ¢s mother lived. During the car drive, Mr Pettigrove killed Mr Rose. Before later committing suicide, Mr Pettigrove told police that he had acted on impulse, believing that Mr Rose had killed him in a past life. Mr Roseà ¢Ã¢â€š ¬Ã¢â€ž ¢s family brought an action against the health authority claiming negligence on its part. The respondents alleged that the appellants owed Mr Rose and his relatives a duty to prevent Mr Pettigrove causing harm to Mr Rose, which it failed to do and as a consequence, they suffered nervous shock brought about by Mr- Roseà ¢Ã¢â€š ¬Ã¢â€ž ¢s death.[5] Procedural History At first instance, Elkaim DCJ, the trial judge of the New South Wales District Court found that there was no breach of duty of care as the respondents had failed to establish, that the risk was reasonably foreseeable and à ¢Ã¢â€š ¬Ã‹Å"not insignificantà ¢Ã¢â€š ¬Ã¢â€ž ¢ that a reasonable person would have taken precautions against it.[6] On appeal, the New South Wales Court of Appeal (consisting of Beazley P, Macfarlan JA, and Garling J dissenting) held that à ¢Ã¢â€š ¬Ã‹Å"[t]he Hospital owed Mr Rose a common law duty to take reasonable care to prevent Mr Pettigrove causing physical harm to Mr Roseà ¢Ã¢â€š ¬Ã¢â€ž ¢,[7] and that that duty had been breached by the manner of discharge. By special leave, the appellants appealed to the High Court of Australia. Decision and Judicial Reasoning On the 12th of November 2014, the High Court (consisting of French CJ, Hayne, Bell, Gageler and Keane JJ) unanimously allowed the appeal. The Court held that the appellants did not owe the alleged co mmon law duty of care to Mr Rose and the respondents as this duty was inconsistent with the statutory obligations prescribed by the MHA. Referring to the judgement in Sullivan v Moody,[8] the High Court highlighted the difficulty in determining the existence and nature and scope of a duty of care. The difficulties included where (a) the nature of the harm suffered is caused by criminal conduct; (b) the defendant has a specific discretion or obligation under the existence of a statutory power; (c) the class of persons to which a duty is owed to is difficult to confine and (d) there is a need to preserve legal principles, or a statutory scheme.[9] Although each of these areas were observed to be relevant to the case, the Court concentrated on the second point in particular when reaching its decision. The Court concluded that the provisions of the MHA, which prohibited the detention or the continued detention of an individual unless no other less restrictive care was available, w as inconsistent with a common law duty of care requiring regard for the safety and welfare of those whom a mentally ill person may come into contactwithwhennotà ¢Ã¢â€š ¬Ã¢â‚¬ detained. Emphasis on à ¢Ã¢â€š ¬Ã‹Å"Controlà ¢Ã¢â€š ¬Ã¢â€ž ¢ The MHA manifested the need for mentally ill patients to à ¢Ã¢â€š ¬Ã‹Å"receive the best possible care and treatment in the least restrictive environmentà ¢Ã¢â€š ¬Ã¢â€ž ¢[10] which, inherently favoured Mr Pettigroveà ¢Ã¢â€š ¬Ã¢â€ž ¢s discharge. Nonetheless, the objectives of the MHA, were equally concerned with the à ¢Ã¢â€š ¬Ã‹Å"controlà ¢Ã¢â€š ¬Ã¢â€ž ¢ of mentally ill persons including control intended to protect and prevent such persons, and others, from serious harm. Mr Pettigrove was admitted with principal diagnosis of exacerbation of chronic paranoid schizophrenia. He was certified by the medical superintendent to be mentally ill and involuntary admission and detention was found to be required.[11] During the early hours of the morning in the hospital, a nurse documented Mr Pettigrove to be à ¢Ã¢â€š ¬Ã‹Å"clearly experiencing psychotic phenomenonà ¢Ã¢â€š ¬Ã¢â€ž ¢, à ¢Ã¢â€š ¬Ã‹Å"pre-occupied and agitatedà ¢Ã¢â€š ¬Ã¢â€ž ¢ and having admitted to à ¢Ã¢â€š ¬Ã‹Å"voices that bother himà ¢Ã¢â€š ¬Ã¢â€ž ¢.[12] On the morning of the drive to Victoria, a psychiatrist assessed Mr Pettigrove and said that he did not have any distressing thoughts during the night. However, this was inconsistent with the nursesà ¢Ã¢â€š ¬Ã¢â€ž ¢ notes. Moreover, it is difficult to accept that the observations of that morning formed a sufficient basis to conclude the symptoms for which Mr Pettigrove had been admitted to hospital had disappeared. It may be argued that Mr Rose volunteered to drive Mr Pettigrove to Victoria and therefore he was adequately placed to exercise his own judgment about his ability to protect himself from harm.[13] However, Mr Roseà ¢Ã¢â€š ¬Ã¢â€ž ¢s offer was to drive Mr Pettigrove when he was à ¢Ã¢â€š ¬Ã‹Å"well enoughà ¢Ã¢â€š ¬Ã¢â€ž ¢[14] which clearly implied that Mr Rose relied on the hospital forming the view that, before he was discharged, Mr Pettigrove was fit to travel with him to Victoria. Therefore, Mr Roseà ¢Ã¢â€š ¬Ã¢â€ž ¢s safety was dependent upon an astute judgment by the appellants. In light of these observations, there was a need for control of Mr Pettigrove by continued detention. For the purposes of complying with statutory obligations, Mr Pettigroveà ¢Ã¢â€š ¬Ã¢â€ž ¢s involuntary treatment order could have been revoked and he could have simply been encouraged to remain in hospital as a voluntary patient to undergo further treatment. Further, these observations suggest that there was a à ¢Ã¢â€š ¬Ã‹Å"reasonably foreseeable riskà ¢Ã¢â€š ¬Ã¢â€ž ¢ that was à ¢Ã¢â€š ¬Ã‹Å"not insignificantà ¢Ã¢â€š ¬Ã¢â€ž ¢ that without appropriate treatment, Mr Pettigrove might cause harm to himself or a third party. Referring to the present case, the High Court stated that : à ¢Ã¢â€š ¬Ã‹Å"[For] a mentally ill person, the risk of that person acting irrationally will often not be insignificant, farà ¢Ã¢â€š ¬Ã¢â‚¬Ëœfetched or fanciful. And, in such cases, there will often be a risk that the irrational action will have adverse consequencesà ¢Ã¢â€š ¬Ã¢â€ž ¢.[15] These observations would have led a reasonable psychiatrist in the appellantsà ¢Ã¢â€š ¬Ã¢â€ž ¢ position, to continue to detain Mr Pettigrove and not consign him into the care of Mr Rose for a long road trip on their own. A reasonable psychiatrist would have asserted that Mr Pettigroveà ¢Ã¢â€š ¬Ã¢â€ž ¢s symptoms were liable to fluctuate and that there was no guarantee of recovery from a psychotic episode.[16] Therefore, a duty of care was owed to third parties and that duty was subsequently breached by the health authority in discharging Mr Pettigrove into the custody of Mr Rose. As a result, the appellants failed to uphold the aspect of à ¢Ã¢â€š ¬Ã‹Å"controlà ¢Ã¢â€š ¬Ã¢â€ž ¢ pursuant to the MHA. A Question of Public Policy Section 20 of the MHA ultimately promotes the civil rights of mentally ill persons by requiring minimum interference with their liberty. InCarrier v Bonham,[17]McPherson J referred to à ¢Ã¢â€š ¬Ã‹Å"more humane methods of treatmentà ¢Ã¢â€š ¬Ã¢â€ž ¢for mental health patients, enabling à ¢Ã¢â€š ¬Ã‹Å"greater liberty of movementà ¢Ã¢â€š ¬Ã¢â€ž ¢.[18] However, the right to dignity, autonomy and respect of mentally ill persons should not detract from the more imperative right to proper care and treatment, including protection. This priority assumes even greater significance when the personà ¢Ã¢â€š ¬Ã¢â€ž ¢s insight into his or her mental illness is impaired and their decision-making capacity is affected. [19] Such was the situation of Mr Pettigrove and therefore, the necessity for control through detention, should have outweighed the requirement for à ¢Ã¢â€š ¬Ã‹Å"least restrictiveà ¢Ã¢â€š ¬Ã¢â€ž ¢ care and treatment. Implications T he decision of this case creates a high level of immunity for psychiatrists and the institutions through which they provide services, from tortious liability for violent conduct of patients upon failure to impose involuntary detention or maintain involuntary detention.[20] This decision also reinforces the judgement of Sullivan v Moody, that when determining the nature and scope of a duty of care in particular circumstances, regard must be had to statutory obligations, which may serve to circumscribe or override the duty otherwise owed.[21] Conclusion The appellants owed, and breached a duty of care to Mr Rose and the respondents by discharging Mr Pettigrove. Such an act involved an imprudent exercise of the statutory duty under the MHA as the Act was equally concerned about the à ¢Ã¢â€š ¬Ã‹Å"controlà ¢Ã¢â€š ¬Ã¢â€ž ¢ of mentally ill patients as with their liberty. The High Court failed to evaluate this necessity of control against a least restrictive environment. Nevertheles s, the decision of the case heightens the tension surrounding both the balance between the liberty of mental health patients, and the protection of such patients and the wider community, as well as the coexistence of statutory powers and common law liability. Bibliography Articles/books/reports Freckelton, Ian, à ¢Ã¢â€š ¬Ã‹Å"Legal Liability for Psychiatristsà ¢Ã¢â€š ¬Ã¢â€ž ¢ Decisions about Involuntary Inpatient Status for Mental Health Patientsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2014) 22(2), Journal of Law and Medicine 280-289 Freckelton, Ian, à ¢Ã¢â€š ¬Ã‹Å"LiabilityofPsychiatristsforFailuretoCertifyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2003) 10(2) Psychiatry, Psychology and Law 397-404 Peterso, Kathryn, à ¢Ã¢â€š ¬Ã‹Å"Where is the line to be drawn? Medical Negligence and Insanity in Hunter Area Health Service v Preslandà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2006) 28(1), Sydney Law Review 181-196 Rangarajan, Shrikkanth and Bernadette McSherry, à ¢Ã¢â€š ¬Ã‹Å"To Detain or Not to Detain: A Question of Public Duty?à ƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ (2009) 16(2), Psychiatry, Psychology and Law 288-302 Scott, Russ, à ¢Ã¢â€š ¬Ã‹Å"Hunter Area Health Services v Presland: Liability of Mental Health Services for Failing to Admit or Detain a Patient With Mental Illnessà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2006) 13(1), Psychiatry, Psychology and Law 49-59 Scott, Russ, à ¢Ã¢â€š ¬Ã‹Å"LiabilityforHealthServices for not Involuntarily Detaining and Treating a Mentally Ill Personà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2015) 22(1), Psychiatry, Psychology and Law 1-31 Scott, Russ, à ¢Ã¢â€š ¬Ã‹Å"Liability of Psychiatrists and Mental Health Services for Failing to Admit or Detain Patients with Mental Illnessà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2006) 14(3), Australasian Psychiatry 256-262 Cases Carrier v Bonham [2001] QCA 234 Hunter and New England Local Health District v McKenna [2014] HCA 44 McKenna v Hunter New England Local Health District; Simon v Hunter New England Local Health District [2013] NSWCA 476 Presland v Hunter Area Health Service [2003] NSWSC 754 Sullivan v Moody (2007) 207 CLR 562 Legislation Mental Health Act 1990 (NSW) Civil Liability Act 2002 (NSW) Other Blacker, Wendy, and Tejas Thete, à ¢Ã¢â€š ¬Ã‹Å"Detention or Release: The Common Law and Statutory Dichotomyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2014) Gadens https://www.gadens.com/publications/Pages/Detention-or-release-the-common-law-and-statutory-dichotomy.aspx at 4th April 2015 Leaver, Cameron, à ¢Ã¢â€š ¬Ã‹Å"Hunter and New England Local Health District V Merryn Elizabeth McKenna [2014] HCA 44; Hunter and New England Local Health District V Sheila Mary Simon Anor [2014] HCA44à ¢Ã¢â€š ¬Ã¢â€ž ¢ on Cameron Leaver, Hicksons Health Law Blog (13 November 2014) https://hicksonshealthlawblog.com/2014/11/13/hunter-and-new-england-local-health-district-v-merryn-elizabeth-mckenna-2014-hca-44-hunter-and-new-england-local-health-district-v-sheila-mary-simon-anor-2014-hca-44/ at 3rd April 2015 Merryn Elizabeth McKenna, à ¢Ã¢â€š ¬Ã‹Å"Appellantà ¢Ã¢â€š ¬Ã¢â€ž ¢s Chronologyà ¢Ã¢â€š ¬Ã¢â€ž ¢, Submission in Hunter and New England Local Health Services v McKenna, S142/2014, 25 July 2014 Hunter and New England Local Health District, à ¢Ã¢â€š ¬Ã‹Å"Appellantà ¢Ã¢â€š ¬Ã¢â€ž ¢s Submissionsà ¢Ã¢â€š ¬Ã¢â€ž ¢, Submission in Hunter and New England Local Health Services v McKenna, S143/2014, 25 July 2014 Van de Poll, John and Vahini Chetty, à ¢Ã¢â€š ¬Ã‹Å"Is a Hospital Liable for the Criminal Acts of Its Mental Health Patients?à ¢Ã¢â€š ¬Ã¢â€ž ¢ (May 2014) Holman Webb Lawyers https://www.holmanwebb.com.au/publications/is-a-hospital-liable-for-the-criminal-acts-of-its-mental-health-patients at 3rd April 2015 [1] [2014] HCA 44. [2] Mental Health Act 1990 (NSW) s 9 (definition of à ¢Ã¢â€š ¬Ã‹Å"mentally ill personà ¢Ã¢â€š ¬Ã¢â€ž ¢). [3] Ibid s 20. [4] Ibid s 4(1). [5] John Van de Poll and Vahini Chetty, à ¢Ã¢â€š ¬Ã‹Å"Is a Hospital Liable for the Criminal Acts of its Mental Health Patients?à ¢Ã¢â€š ¬Ã¢â€ž ¢ (May 2014) Holman Webb Lawyers https://www.holmanwebb.com.au/publications/is-a-hospital-liable-for-the-criminal-acts-of-its-mental-health-patients at 3 April 2015. [6] Civil Liability Act 2002 (NSW) s 5B (1). [7] McKenna v Hunter New England Local Health District; Simon v Hunter New England Local Health District [2013] NSWCA 476, [108] (Macfarlan J). [8] Sullivan v Moody (2007) 207 CLR 562. [9] Ibid [50]. [10] Mental Health Act 1990 (NSW) s 4(2). [11] Merryn Elizabeth McKenna, à ¢Ã¢â€š ¬Ã‹Å"Appellantà ¢Ã¢â€š ¬Ã¢â€ž ¢s Chronologyà ¢Ã¢â€š ¬Ã¢â€ž ¢, Submission in Hunter and New England Local Health Services v McKenna, S142/2014, 25 July 2014, 2. [12] Dr Russ Scott, à ¢Ã¢â€š ¬Ã‹Å"LiabilityforHealthServices for not Involuntarily Detaining and Treating a Mentally Ill Personà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2015) 22(1) Psychiatry, Psychology and Law 1, 4. [13] Hunter and New England Local Health District, à ¢Ã¢â€š ¬Ã‹Å"Appellantà ¢Ã¢â€š ¬Ã¢â€ž ¢s Submissionsà ¢Ã¢â€š ¬Ã¢â€ž ¢, Submission in Hunter and New England Local Health Services v McKenna, S143/2014, 25 July 2014, 10 [54]. [14]14 Ibid 4 [21]. [15] Hunter and New England Local Health District v McKenna [2014] HCA 44, [31]. See also Presland v Hunter Area Health Service [2003] NSWSC 754. [16] McKenna v Hunter New England Local Health District; Simon v Hunter New England Local Health District [2013] NSWCA 476, [133] (Macfarlan J). [17] Carrier v Bonham [2002] QCA 234. [18] Ibid [36] (McPherson J). [19] Dr Scott Russ, à ¢Ã¢â€š ¬Ã‹Å"LiabilityforHealthServices for not Involuntarily Detaining and Treating a Mentally Ill Personà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2015) 22(1) Psychiatry, Psychology and Law 1, 26. [20] Ian Freckelton, à ¢Ã¢â€š ¬Ã‹Å"Legal Liability for Psychiatristsà ¢Ã¢â€š ¬Ã¢â€ž ¢ Decisions about Involuntary Inpatient Status for Mental Health Patientsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2014) 22(2), Journal of Law and Medicine 280. [21] Wendy Blacker and Tejas Thete, à ¢Ã¢â€š ¬Ã‹Å"Detention or Release: The Common Law and Statutory Dichotomyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1 December 2014) Gadens https://www.gadens.com/publications/Pages/Detention-or-release-the-common-law-and-statutory-dichotomy.aspx at 4 April 2015.