Effect Of Cohabitation On The Male And Females - 1287 Words

Today it is the order of the day to find people involved and living together in sexual unions without actually getting married. Research has it that over 60% of marriages today derive their basis form prior cohabitation. However, less than a half of such unions end up in marriages of if they end up in marriages; the marriages themselves are never satisfied. According to statistics, over 46% of marriages derived from cohabitation today results in divorce cases and the worsening effects is even higher when the couple involved have cohabited severally in the past. The impacts of cohabitation have no positive effects on the male and females involved or even the children. Studies indicate that cohabiting parents spend most of their moneys on drugs and alcohol irrespective of whether they have children or not (Bradley Corwyn, 2004). The aspects of living in cohabitation unions whether there is a definite plan to get eventually married does not indicate a better path for marriages as compa red to forthright marriages. Researches on marriage qualities between cohabitation and actual marriages show poor conditions for cohabitation unions in all the aspects of the wedding. An analysis of children health between those born from cohabiting and those taken from married couples indicate quite ill health from those children born from cohabiting couple (Osborne McLanahan, 2007). Furthermore, the relationships between the males and females involved in cohabitation going by research areShow MoreRelatedCohabitation and Its Effect on Rise in Divorce Rate1117 Words   |  5 PagesEffect of Cohabitation on the Rising Divorce Rate The rise of the divorce rate seems to be due to the lack of commitment or understanding of love and longevity in a marriage. Cohabitation can be defined as an arrangement whereby two people decide to live together on a long term or permanent basis in an emotionally and /or sexually intimate relationship (Brannon 2008). Cohabitation is seen as the best way to understand a prospective mate in terms of living and financial stabilityRead MoreThe Pros And Cons Of Cohabitation Before Marriage1563 Words   |  7 PagesThe Pros and Cons of Cohabitation before Marriage Introduction Social scientists have defined cohabitation as a situation where two adults, male and female live together in a relationship that is intimate and non-marital. The two make living arrangements without legal bounds to stay together before getting married. In most of the countries and in this case in the United States, cohabitation is a common feature among the American family life (Stokes Raley, n.d). It has become a typical pathway toRead MoreDoes Gender Play A Role?1596 Words   |  7 Pagesdecade has revealed substantial increases in the number of individuals having pre-marital sex. Current estimations suggest that 82% to 95% of Americans have had pre-marital intercourse (Renfrow and Bruce, 2014). To understand why an individual (male or female) will choose to have sex, all underlying factors must be examined. Pre-marital sex is a social issue. The cultural ‘norm’ that once existed has changed. Prior to the twentieth century, sexual activity before marriage was not so cially acceptableRead MoreCohabitation Before Marriage Essay1674 Words   |  7 PagesNowadays, the pre-martial cohabitation concept has been widely used across many places. The current generation tends to cohabit outside of marriage at least once in their lifetime. Bruce Wydick argued that, â€Å"cohabitation may be narrowly defined as an intimate sexual union between two unmarried partners who share the same living quarter for a sustained period of time’’ (2). In other words, people who want to experience what being in a relationship truly is, tend to live under one roof and beRead MoreCohabitation: A Trial Period Before Marraige? Essay883 Words   |  4 PagesCohabitation: A Trial Period before Marriage? Marriage can be a frightening thing for anyone. The act of marriage can bring fear such as commitment, as well as fears associated with living together and sharing everything. This, in turn, can lead to one or both parties feeling vulnerable. A common approach to calm these fears and vulnerabilities is cohabitation. For many, cohabitation can seem as a transition period for couples to adjust to living with each other before marriage. In fact, cohabitationRead MoreWhy I Should Interview With My Parents1668 Words   |  7 PagesI noticed certain themes arise such cohabitation, the modern family role, and the financial hardships many face. These three themes will be discussed in profoundness during the paper because they were the themes that seemed to come up the most in the interview and related back to Marla and Mike overwhelmingly. In the interview, we discussed cohabitation a plethora due to the fact Marla and Mike had lived together for years leading up to marriage. Cohabitation is known as living together as sexualRead More‚Äà ²a Family Can Be Defined as a Married Heterosexual Couple and Their Children‚Äà ´. How Have Social Scientists Challenged This Kind of Conventional Definition of the Uk Family?1724 Words   |  7 Pagesare other structures of family raised since the traditional family was declined in the late 1960s to 1970s (Cheal, D. 1991:6). It is suggested that the nuclear family has been diversified into other different structures such as extended family, cohabitation, homosexual family, lone-parent family and step family (Sherratt, N. and Hughes, G.2004:75). First, the extended family is a family more than one couple or pair of parent-children with family ties and inter-support of practical. Mostly are intergenerationalRead MoreBenefits Of A Single Rent Check1498 Words   |   6 Pagesrelationship instability, negatively affects health, and even has negative impacts on children. The goal of cohabiting for most couples is to draw closer together, and while living together before marriage does affect a couple’s relationship, the effects are generally not positive. Sharing a living space does not necessarily mean sharing a social life for cohabiting couples. According to Waite’s research, many couples who begin living together have independent social lives and, at times, separateRead More A History Of Marriage And Divorce: Cohabitacion Can Result in a Positive Outcome1342 Words   |  6 Pagesextinctions to the rise of technology, the world is constantly on a path of changes. And, even though not all events have been pleasant experiences, humans have definitely had the chance to learn from those happenings: one example being, marriage and its effects on family development. Since the beginning of time, open relationships between people, one reason being for the purpose of reproduction, have existed. It is simply part of human nature to bond with others; human instinct. History also shows that legalRead MoreThe Decrease of the Nuclear Family746 Words   |  3 PagesDecrease in the amount of nuclear families There are several possible reasons for the decrease in the number of nuclear families, particularly in the past forty years. This includes rising cohabitation, higher divorce rates, secularisation, rising same sex relationships, more career seekers and the rise in feminism. Firstly, a nuclear family is a family consisting of a man and woman (usually married) in a sexual relationship with one or more children. One reason for this type of family becoming

The Health Records Of Healthcare - 1021 Words

The health record has been around for many years, and it first started with a group of individuals in the 1920’s to realize that documenting health care data provided better quality care. Healthcare providers recognized that they were able to treat patients more accurately with a documented history of the patients. It wasn’t until the 1980’s that healthcare professionals started to venture out into the computerized healthcare technology. In the 90’s technology was making gains and healthcare continued to venture forward into the modern more computerized world of healthcare informatics. One of the revolutionary feature of this era was the ability to get patients test results via computers, the only downsize was that they were only attainable through that computer alone. That type of information had no way of traveling though another computer. By the year 2000, a push to make electronic records began due to the spike of patient death and injuries due to medical errors by healthcare providers. In an article written in 2009 shortly after President Obama took office, it was mentioned that President Barack Obama wanted to computerize the nation’s health care records in five years. But many concerns came with this notion such as money, time and specialized training. The total cost of this health care initiative plan would cost at least $75 billion to $100 billion dollars over next the ten years. They believed that one of the biggest costs in this plan would be trainingShow MoreRelatedElectronic Health Record : Electronic Healthcare Record1257 Words   |  6 PagesElectronic Health Record An Electronic Health Record (also known as EHR) is an official health record for a patient that is stored with multiple facilities and agencies. The main purpose of this electronic system is to improve efficiency, quality of care, and reduce costs. How can one system possibly do all these improvements to health records? Well let’s break it down to simpler terms. It will improve efficiency for individuals seeking healthcare from a different facility in the future. There willRead MoreElectronic Health Records And The Healthcare Field946 Words   |  4 Pagestraditional systems to electronic record systems in the healthcare field within the last couple decades has made a huge impact. Patient records, risk management, planning, staff, and more in the organization are affected by the IT staff. â€Å"The penetration of Internet access, mobile technologies and social networks collectively offer a future in which it is possible to deliver highly personalized care without necessari ly having to do it in person, or even with a doctor.†(Healthcare IT News, n.d.) Many hospitalsRead MoreElectronic Health Records On The Healthcare Field1289 Words   |  6 PagesIntroduction An electronic health record (EHR) is a digital version of a patient’s paper chart (Appari Johnson, 2010). EHRs are immediate, patient- focused data that make report accessible quickly and firmly to certified users. An EHR system is assembled to go further than regular medical information gathered in a doctor’s office and can be comprehensive of an extensive view of a patient’s care (Appari Johnson, 2010). EHRs can: Encompass a patient’s , diagnoses, medical record, prescriptions, treatmentRead MoreElectronic Health Records And Healthcare Today2198 Words   |  9 PagesElectronic Health Records and Healthcare Today Kevin Joseph Nova Southeastern University Technology and Healthcare Today In a healthcare world that operates on stringent budgets and margins, we begin to see the need for a higher capacity healthcare delivery system. This in turn puts pressure on the healthcare organizations to ensure higher standards of patient care, and compliance with the reform provisions. However, these are the harsh realities of today’s healthcare environmentRead MoreE Health Records : The Healthcare And Its Ancillary Industries838 Words   |  4 Pagesmillennial being extremely health conscious, it has given impetus to the healthcare and its ancillary industries. Combing this consciousness with technology gives invention to new products lines like wearable wellness products. With the Pentagon investing in e-health records the government is giving a clear indication that it wants to provide better health services. E-health records will help reduce the cost of health care as you can email your doctor your medical records. Obama Care Act has startedRead MoreElectronic Health Record : The Electronic Healthcare System1487 Words   |  6 Pagesaffected how people live their lives. Technology is also a large part of the healthcare system today. There are many electronics and technologies that are used in health care such as electronic health record, medication bar code scanning, electronic documentation, telenursing, and there are many more forms of technology that impact nursing. One technology that stands out is the electronic health record. The electronic health record, also referred to as EHR, is an electronic version of a patient’s chartRead MoreThe Impact Of Electronic Health Records On Healthcare Delivery1864 Words   |  8 PagesNursing: The Impact of Electronic Health Records Renee M. Bourgeois, Alisha N. Kifer, Brittany R. Walsh Clemson University â€Æ' Abstract This paper describes the overall effects of electronic health records (EHRs) on healthcare delivery. It discusses the effects on quality of patient care, timeliness of access to patient information, efficiency, and errors. The paper also mentions implications for the patient and the nurse. In general, EHRs helped improve the quality of patient care because accessRead MoreElectronic Health Records Systems And Healthcare Facilities1628 Words   |  7 PagesHospitals and healthcare facilities have been expanding throughout every state in America. With that comes, the growth of EHR systems. With the help of HIM directors and health administrators, more and more healthcare facilities, are deciding on the adoption of different kinds of systems to assist in patient care quality. There are many types of electronic health record systems and each of them comes with their benefits and drawbacks. When implementing EHR systems, managers take major risks for theirRead MoreElectronic Health Record s And Its Effect On Healthcare Quality1507 Words   |  7 Pagesas CIS) and the effect it has on healthcare quality. The public depends on healthcare providers to help heal them and healthcare providers depend on CIS to help them heal the public. Health information technology is offering inventive ways for technology to meet the demanding needs of America’s growing population of the sick and aging. Electronic health records (referred to as EHRs) are on the forefront of this movement. EHRs allow a patient’s health records (clinical, lab results, medications)Read MoreThe Electronic Health Records Has Revolutionized Healthcare1666 Words   |  7 PagesWhat are EHR s? The introduction of electronic health records has revolutionized healthcare as we know it today. Instead of using paper records, which can easily get lost, damaged, or even stolen. However, now that most healthcare providers have switched to the electronic health records, it is easier to manage the data, edit the data, and share the data to other healthcare providers. The problem is that as many benefits there are to the electronic records, there are just as many threats and problems

Consideration Need Not be Adequate Realistic.

Question: What the term sufficient means in this context and whether the statement is accurate in regards to Australian contract law? Answer: Role of consideration Consideration plays an important role in the formation of a contract. It is one of the most important elements without which the contract does not come into existence. The reason for entering into the contract or being party to it is answered the consideration. If an agreement is deemed to be legally binding then it has to have consideration[1]. Consideration should be something that is of value that is promised to some other person. This refers to as the legal value which is established in connection to the contract[2]. An agreement that is made without including any consideration would be void, however it would not be void when it will be expressed in writing and also it would be registered. This should be registered under the law for the time being in force. In the case, Dunlop Pneumatic Tyre Co Ltd v Selfridge Co Ltd,[3] an act or any forbearance which is undertaken by one party is regarded as the price for the promise that is given by the other party. Thus the promise that has been made would be enforceable[4]. Consideration refers to the stipulation of some price. This price refers to something that has a monetary value. It might be monetary or it might not be holding any monetary value. It is a kind of detriment on behalf of the one who binds himself into the promise[5]. This detriment take the form of waiving off of freedom which that person otherwise would have enjoyed, had he not entered into a promise. In the case, Carlill v. Carbolic Smoke Ball Company[6], the court mentioned that it was sufficient that Carlill suffered some sort of detriment due to the use of that smoke ball as it was mentioned; this could happen even if no benefit was received by the company. Consideration can be said to be anything that can be stipulated according to the will of the promisor. It is the promisor who stipulates the consideration for the promise. This is done by him either directly or indirectly. It is not for the promisee to stipulate the same or proffer something as consideration. Chapel vs. nestle is one of the most important cases that state about the nature of consideration. In this case, a peppercorn was constituted to be a consideration. Therefore, nothing of monetary value was used in this case as consideration[7]. In yet another case, Dunton vs. Dunton,[8] it was held that even if a person waives off his freedom, this would be termed as consideration for the other party. Also in some of the cases it was held that if a person gives up a legal right, this could also be taken as consideration and thus the contract would be valid. Consideration need not be adequate. Inadequate consideration is not an invalid consideration. It can be held as a good consideration. The consideration ought to have values in the eyes of law therefore; an illusionary consideration cannot be taken into consideration[9]. The past consideration cannot be held to be a good consideration. The consideration has to come into existence in lieu with the promise. When the consideration is mentioned and it predates the formation of a promise then this cannot be held to be a good consideration. This was upheld in the case, Roscola vs.Thomas[10], wherein consideration as regards to the soundness of a horse was given before any promi ses were made between the two parties[11]. However, there are several instances wherein the consideration is held in the past, and then this would be considered as a good consideration. These instances refer to the fact when it is provided at the request made by the promisor himself. Another instance could be when both the parties knew that the act would be anyway remunerated. If the promise occurred before any promise was made. If the promise occurred prior to the deed that took place then also the consideration paid would be enforceable. In the case Pao On v. Lau Yiu Long[12], these exceptions to the past consideration were upheld. Sufficiency of consideration refers the fact that it is something which holds some value. It does not have to be proportionate to the promise. It is because; the court would not be able to ascertain the value that is placed on each and every promise. This notion of sufficiency provides that economic freedom to the parties in the contract. If it is required that the consideration would be adequate then this would create difficulties between the parties and also would give rise to uncertainty in the enforceability of the contract. Sufficiency of consideration promotes economic efficiency between the parties as voluntary exchanges can then be made. Nominal consideration is also legal[13]. Therefore, for example if a house is sold by a seller for $1 only then also this would be considered valid. In the case, William vs. Roffey Bros Nicholls Ltd.[14], the English Court of Appeal upheld the validity of the consideration even if it was inadequate. It was held by the court that Roffey Bros paid Williams as they derived a benefit practically, and this was held to be a sufficient consideration. An exception to the general rule of past consideration arose in this case. It was held that practical benefit was given to the person on the fulfillment of some obligation under the contract[15]. It was held that there was sufficiency of consideration in this case. The members of the court had tried to generate the practical benefit principle[16]. This rule states to emphasize on the fact that if any actual performance takes place in lieu of the legal duty that is in existence[17], this would be taken as sufficient consideration. If there is a mere gratuitous promise that is made to the other party, then this would be invalid for the want of consideration. In the case, Stilk vs.Myrick[18] case, the Lord said that if there was a promise to perform a duty and the person was already bound to do the same under the contractual duty then this could not held to be a good consideration. This principle was referred to as the existing legal duty rule. It was held by the Lord that agreements that were made to give effect to the modifications that were one sided then these would be invalid as there was no proper consideration in it. In yet another case, Hawkers vs. Saunders,[19] it was held that when a man is under a moral duty or an obligation wherein no Court of Equity or law could enforce the same, and then these ties of conscience are held to be as the consideration that was sufficient. It was upheld in this case that whenever a person is the defendant and is under a duty to pay as per the principles of equity and conscience then this would be counted as the sufficient consideration. In another case, Coggs vs. Bernard[20], the definition of sufficient consideration was highlighted. In this case, the defendant made a promise to transport safely the casks of the brandy of the plaintiff. While transportation, one of the casks broke and large number of gallons of brandy got lost. It was held by the court that this was the detriment that was suffered by plaintiff and this was in consequence to the promise given by defendant. Hence, it was upheld that this was a sufficient consideration for rendering the support to the contract. Justice Gould said that if an undertaking is given by a man to hold the goods of other people safely and if he does not take utmost care of the same then this would be entitled to be held as a sufficient consideration. This kind of trust paced upon the defendant would be a sufficient consideration to the contract. In the case, Thomas vs. Thomas[21], it was held that motive cannot be taken to be as a sufficient consideration. As consideration is something that holds value, motive could not be said to have any value in the eyes of law and could not be calculated. In this case, a house had been promised to a widow and she promised in return to pay around 1 pound per annum as the rent and she stated that she would maintain the property in a good condition and make repairs if needed. This was held to be sufficient consideration under law as it had an actual value. Another case, Zecevic v The Russian Orthodox Christ the Saviour Cathedral[22], this case talked about the plaintiff who had sued the priest as he had not upheld his duty of performing the funeral service. There was no fee paid by the plaintiff to the priest and therefore no issue of money ever arose between them. Also no particular fee was set and finally it was held that there was no intention to form any kind of legal relations between the parties and therefore there was insufficient consideration as no payment was made. Therefore consideration should be something that is of value and then only it can be taken to be as a sufficient consideration. In the case, Sea-Land Service Inc v Cheong Fook Chee Vincent[23], the same principle of sufficient consideration was also held. Adequate Consideration refers to when a mutual exchange is made between the parties and this is based on a price that is fair enough in accordance of the transaction being made. It means that when the consideration is adequate, the contract is enforceable. For example, a promise is made by B to A that he would sell his house which costs around $100000. However, A in return promises to pay $120 then this consideration would not be at all adequate. However, there can be another instance in which if B tries to exchange those services of worth $50000 then this would be treated as adequate consideration[24]. If the consideration is too certain or it is too inadequate then this would infer that there was no intent to form any kind of contract. The question here arises as to how the court would be able to determine the value of any subject matter. To know whether the subject matter is adequate or not the court goes through two ways, one is by law and the other way is through fact.[25] First ly, when the method of law for calculating adequacy is exercised by the court then, a rule would be applied which states that if there is any sentimental value applied then this would not constitute as an adequate consideration. Also, if the consideration involves such a promise to waive off the right which is not possessed by him then this would be an inadequate consideration[26]. In the case White vs. Bluett[27], the son gave a promise not to complain anyone about the distribution of the property by his father was not an adequate consideration. It was because the son did not possess the right of complaining and therefore he could not exercise that right without even possessing the same. According to the method of fact, the adequacy of the consideration would be taken to be as something which would be of sufficient value and which causes some inducement for the parties to enter into a contract or seal the same. In the case Chappell vs. Nestle,[28] it was held that if there is any k ind of mutual inducement then this would be the most basic type of the exchange. Therefore, the court gives weight age to burden that lies on both the parties to the contract. This onus is levied on the parties before the signing of the contract which is deliberated to be entered into and also the adequacy of the consideration is decided upon by both the parties. For the purpose of proving the adequacy of consideration even the most trifle detriment or benefit would be sufficient enough to form adequate consideration. The existing duty rule was inferred from the contract law of Australia had sought to play a major role in the creation of law of consideration in Australia. This is also supported by a lot of precedents. It was held that the obligations or duties were not to be held as consideration; however, there is a drastic change in the new kind of approach. This rule of existing duty has paved way for solutions to a lot of similar cases that came to the court. Therefore, the consideration has to be sufficient but not adequate[29]. Consideration must be something that has an economic value or even if it is negligible then also it would be sufficient. However, following wishes of some other person cannot hold good and therefore cannot be termed as consideration. In the case Hamer vs. Sadway[30], the above mentioned statement was upheld. In the case, Combe vs. Combe[31], it was again held that a promise that is made by a party not to enforce any claim that is existing would be held as sufficient consideration only when any promise in return was made in the influence of the former[32]. Realistic means which is real or something that is actual[33], however consideration may or may not be actual. It just has to be sufficient. Bibliography Books/Articles/Journals Thampapillai, D., Practical Benefits And Promises To Pay Lesser Sums: Reconsidering The Relationship Between The Rule In Foakes V Beer And The Rule In Williams V Roffey (2015) 34, Australasian Legal Information Institute. Scott, K.,N. From Sailors To Fisherman: Contractual Variation And The Abolition Of The Pre-Existing Duty Rule In New Zealand (2005), (2005) 11 Canterbury Law Review. Giancaspro,M., The Rules for Contractual Renegotiation: A Call for Change, (2014) 1, Australasian Legal Information Institute. Street, T., A., The History and Theory of English Contract Law (Beard Books, 1999). Others Chest of books, Sec. 639. What Constitutes Inadequacy Of Consideration (2017), https://chestofbooks.com/business/law/Law-Of-Contracts-4-1/Sec-639-What-Constitutes-Inadequacy-Of-Consideration.html. Weitzenboec, M., E., English Law of Contract: Consideration (2012), https://www.uio.no/studier/emner/jus/jus/JUS5260/v12/undervisningsmateriale/Consideration.pdf. Twyford, J., W., The Doctrine of Consideration (2002), https://opus.lib.uts.edu.au/bitstream/10453/20049/2/02Wholethesis.pdf . Clarke, J., Consideration (2015), https://www.australiancontractlaw.com/law/formation-consideration.html. Clarke, J., Overview of Australian contract law (2010), https://www.australiancontractlaw.com/law.html. K, Consideration (Part 1 Of 3 Definition And Essentials) (2014), https://kanwarn.wordpress.com/2014/02/21/consideration-part-1-of-3-definition-and-essentials/. Mance, K., L., Contract Consideration (2017), https://www.legalmatch.com/law-library/article/contract-consideration.html. Kier, Post: Explain the statement consideration must be sufficient but (2006), https://counsel.net/chatboards/contracts/topic5/3.31.06.04.51.11.html. Giancaspro, M., A., For Your Consideration: Old Rules, Practical benefit and a New Approach to Contractual Variation (2017), https://digital.library.adelaide.edu.au/dspace/bitstream/2440/84690/8/02whole.pdf. National Para Legal, Introduction to Contracts and Consideration (2017), https://nationalparalegal.edu/public_documents/courseware_asp_files/contracts/Consideration/IntroductionAndConsideration.asp Study, Lack of Consideration in Contract Law (2017), https://study.com/academy/lesson/lack-of-consideration-in-contract-law.html. Swarb, Dunlop Pneumatic Tyre Co Ltd V Selfridge And Co Ltd: Hl 26 Apr 1915 (2017), https://swarb.co.uk/dunlop-pneumatic-tyre-co-ltd-v-selfridge-co-ltd-hl-26-apr-1915/. Swarb, Combe V Combe: CA 1951 (2017), https://swarb.co.uk/combe-v-combe-ca-1951-2/. The Voice of Political Nonsense, The Relationship between Trade Openness and Economic Growth (2016), https://thevoiceofpoliticalnonsense.wordpress.com/2016/04/ List of Cases Carlill v. Carbolic Smoke Ball Company [1893] 1 QB 256 Chappell vs. Nestle [1959] UKHL 1 Combe vs. Combe, [1951] 2 KB 215 Dunlop Pneumatic Tyre Co Ltd v Selfridge Co Ltd [1951] UKHL 1 Dunton vs. Dunton 1892 18 VLR 114 Hamer vs. Sadway 124 N.Y. 538 Hawkers vs. Saunders (1782) 98 ER 1091 Pao On v. Lau Yiu Long [1979] UKPC 17 Roscola vs.Thomas (1842) 3 QB 234 Sea-Land Service Inc v Cheong Fook Chee Vincent [1994] 3 SLR 631 Stilk vs.Myrick [1809] EWHC KB J58 Thomas vs. Thomas (1842), 2 QB 851 White vs. Bluett (1853) 23 LJ Ex 36 William vs. Roffey Bros Nicholls Ltd [1989] EWCA Civ 5 Zecevic v The Russian Orthodox Christ the Saviour Cathedral [1988] O.J. 1282 (Sup.)

Psychology Essays (256 words) - Psychology, Psychoanalysis

Psychology Karen Horney was a Freudian analyst was studying dream interpretation and developed a better understanding of dream interpretation. In her process she incorporated many ideas of other psychologist to her own theories which included Freud's unconscious and early childhood. Freud had more emphasis on the on the manifest content while Horney focused on the latent content. Karen also believed that a crucial aspect to analysis, the transference- countertransference phenomenon and hot it can be appraised in the dream. However karen did believe that dreams are like the road to the unconscious like Freud did. Horney's holistic approach to the nature of human was more effective in the growth of a person toward totally maturity. This was a interesting fact to know because the word growth did not appear in any of Freud's writings and this was a crucial part. Karen believed that the dream is the best way of evaluating ones growth. Horney believed a dream consisted of many metaphors with und erlying meaning. This would help us understand one's internal conflicts. Also most analysts believe it is very important for the doctor patient relationship to be strong because it will be a more successful psychoanalysis. The interpretation of dream reflect the theory, value system, motivation and knowledge of the human personality. Unlike freud who felt that the dream had underlying wishes. While Horney say dreams as a more holistic expression of the patient's current conflicts. The Dream is a composite of symbols or metaphors the show struggles between fantasy or reality.