Opportunity Of Top Glove Entering Indonesia Marketing Essay

Opportunity Of Top Glove Entering Indonesia Marketing Essay 1.0 Introduction Top Glove was established in 1991 as a small factory with three production lines, but it has since grown exponentially to become the largest rubber glove manufacturer in the world (Top Glove, 2013). It was listed on Bursa Saham Kuala Lumpur on 27th march, 2001 and promoted to Main Market of KLSE in 16th may 2002. The company have shareholder funds worth RM1.28b with annual turnover of RM2.31 billion at financial year ended on 31st August 2012. The companys current headquarters is located in Malaysia at Jalan Meru Klang, Selangor. The company currently have sales office in China, Thailand, USA, and Germany. In order to capture more global market share, the company has taken a rapid expansion of its capacity. The companys manufacturing facilities which are located at Malaysia, Thailand, and China grew to 24 from only 5 when it was listed in BSKL on 2001. Top Glove Corporation Berhad wholly-owned the subsidiary of Top Glove in Thailand and China. The company represents 26 percent of the market share worldwide (Tan Sri Dato Sri Lim, 2008). Currently, the company exports to its 1,800 customers in more than 185 countries around the world (Top Glove, 2013). The companys products are exported and available in most countries in North America, Latin America, Europe, Middle East and Asia region (Tan Sri Dato Sri Lim, 2011). The vision of Top Glove is to strive to be the worlds leading manufacturer with excellent quality glove products that enrich and protect human lives while the mission statements is to be world class glove manufacturer providing top quality product with excellent services through continuous improvement and innovation. The company offers 13 types of rubber gloves to the public such as latex examination gloves, nitrile examination gloves, vinyl examination gloves, surgical glove, clean disposable gloves, general purpose glove and others. Top glove have the capabilities to produce total production capabilities of 40.3 billion pair of glove annually. This because the company has 24 factories and 462 manufacturing line that can produce vast amount of glove. Indonesia is a tropical country located near Top Glove home country, Malaysia. Tropical weather in Indonesia allows for fertile growth of rubber trees that are used in production of latex. One of the agricultural industries in Indonesia is rubber industry (CIA, 2012). The large and fertile soil is one of the geographic advantages of the country from Top Gloves view. It enables large supplies of latex to facilitate the production of gloves to processing and manufacturing plants of Top Glove. Indonesia is a country that posses one of the lowest labour cost in the world. Indonesia currently has 248.6 million residents which is the 4th most populated country in the world (CIA, 2012). Cheap labour cost coupled with large supply of raw material makes it a suitable location for Top Glove to expand into. This factor will save the cost of production thus enable the company to sell their product at cheaper price, so that they can compete better in global market. Indonesia also experienced active reform in business regulation in recent years and is among the top 50 economies improving the most and the top 5 within the East Asia and Pacific Region (The World Bank and International Corporation, 2012). 14% of its GDP is consists of agricultural sector (CIA, 2012). The inflation rate also improved from 5.4% in 2011 to 4.5% in 2012 (CIA, 2012). According to Dean (2001), doing business and investment in most parts of Indonesia is relatively safe and profitable. Thus, the stable economic and political environmental encouraged Top Glove to expands to the country. 2.0 Analysis There are several reasons that attract Top Gloves Corporation to explore into Indonesia market. However, entering a foreign may not only brings gains but also shortcomings. Hence by analyzing the respective country, we able to understand is it significant for Top Gloves Corporation to invest or to enter Indonesia market. According to Managing Director of Top Gloves Corporation KM Lee, he stated that the rise in healthcare standards tied with the increase in the global population had increases the demand of medical gloves (Top Gloves, 2013). Meanwhile, Chairman Tan Sri Lim Wee Chai indicated that the rise in the labor cost with the introduction of the minimum wage policy had forces the group to increase its glove prices by 3-5 per cent, depending on the type of product. With the rise on demand of medical gloves, thus, Top Gloves Corporation tends to expand their production line (Top Gloves, 2013). Besides, the increase of labor cost due to minimum cost forcing the corporation to look after a lower-cost country, as the labor cost will be lower. From the literature findings, John Tanner (1996) found that Indonesia is low cost skilled labor that benefits to Top Gloves Corporation. Furthermore, Indonesia is a country that rich with natural resources that match the Top Gloves nature of business that is the rubber (Doing Business, 2012). Thus, expanding a plant into Indonesia market may lead the corporation to gain more profit, as the production line can be more effective and efficient. Apart from that, Indonesia was a main attraction for Top Gloves Corporation because the country of Indonesia able to offer a lower production cost as the labor cost resources is lower in price. According to Sari Shaviriyani (2006), a statistic shows that Indonesias population is the world fourth largest. The workforces over the country are huge and young enable the labor cost to be lower as the workforce supply is higher than the demand forcing the wages to be lower down. More to the point, the workforces are young and energetic allowing Top Gloves production line to produce more effectively. In addition, Indonesias government does encourage more foreign investment by establishing certain departments and supportive bodies in order to speed up the investment licensing procedures (Sari Shaviriyani, 2006). Besides, some incentives are also provided to foreign investors, including tax incentives that enable Top Gloves Corporation to increase their companys profit by paying fewer taxes (Sari Shaviriyani, 2006). However, this was theoretically to benefit the public interest, as the increase in competition in these open sectors will force the companies to operate efficiently and cut prices to win market share (Sari Shaviriyani, 2006). In that sense, it will creates a win-win solution for the country itself and the foreign company as the economy of Indonesia able to boom and the citizen of Indonesia able to enjoy the goods at lower prices meanwhile the operation can be carry on at a lower price. However, every pro comes with a con as Indonesia offers a lot of gains to attract foreign company to invest into Indonesia but there is still a bit of shortcoming (Sari Shaviriyani, 2006). Top Gloves Corporation had to suffer high initial investment, as the country of Indonesia had no technological deepening of manufacturing sector production and exports creating a mess for Top Gloves Corporation to take initiative to invest. Furthermore, home country of Indonesia drives to pick-up all the skills and technique from Top Gloves Corporation that makes them a future threat. Additionally, lack of highly educated people can also be a shortcoming of Top Gloves Corporation as the company focuses more on hiring highly educated people. This reason is because the operation of the machine maybe too technical and may need a knowledgeable people to ensure everything operates in effective and efficient way. Lastly, ecology can be also another shortcoming for the Top Gloves as the climate of Indonesia changes rapidly that may affect the fertile of the plantation causing a shortage in the resources. Some of the global climate changes that might affect the plantation of Indonesia such as rising sea levels, rising air temperatures, changes in rainfall period, and extreme climate change. Similarly, the influence of a combination of raising temperature in regions, changes in the level of precipitation and the intensity of drought/flood (Sari Shaviriyani, 2006). Although, climate changes may sound serious but open burning on the forest as the tradition of Indonesia in order to maintain the plantation to be fertile would be more devastating as it will bring down the goodwill of Top Gloves Corporation (Dyna Rochmyaningsih, 2012). 3.0 Recommendation The current strategies used by Top Glove are exporting and wholly owned subsidiary. Top Gloves had done successfully with both of the strategy, however, they are continuing in seeking the new way to expand to more and more country. We recommended Top gloves to expand into worldwide, which is acquisition strategy. One of the successful companies who using acquisition strategy is Showa Co. who acquired all of Tillotsons Best Glove operations and subsidiaries, which are helping to create a global leader position in the glove manufacturing (Showa Glove, 2009). Acquisition of the company in the same industry will improve the company strength in production, reaching customer, and even the operation through synergy strategy such as the expertise and machinery (Showa Glove, 2009). The advantages of acquisition brings to the Top Gloves is reduced the cost. Top Gloves are able to generate the raw material needed to process the gloves like palm kernel shell and latex from Indonesia Besides, the labour cost in Indonesia is much cheaper compared with Malaysians labour cost. We suggest that Top Gloves should maintain their current expansion strategy which is exporting and building the manufacture in foreign country, at the same time, adopt the acquisition to take over the related company in foreign markets. Once it is confirmed that the market possesses a huge potential for gloves market, Top Gloves may set up a manufacture plant in Indonesia and implement backward integration by taking over the related company such as supplier for palm kernel shell firms. Top Glove should be aware of the policy changes. Policy changes exist due to unstable condition in term of political pressure, economic trend, social unrest and restriction of the ownership of nondomestic company (Wild, J. J., Wild, K. L., Han, J. C. Y., 2010). According to Boediono (2005), to achieve long term business profit in a dynamic changing country like Indonesia, it is important to maintain awareness between economies and political issues. A strong professional team must be developed to maintain high policy effectiveness. Hence, to managing threats of policy changes, Top Glove can gather more foreign information in Indonesia through recruit foreign proficient consultant who understands the foreign culture well. Hiring local managerial talent is the best ways in foreseen and helps in explore business opportunity, it may facilitating the procedures in getting approval and application of local operation and result in attracting more local people join to the new established company. Besides, government will make change on economic policy and legal rules in order to forcing the business to update the way they do the business (External Environment Theory, 2013). Thus, Top Glove must managing political-risk services and issues carefully which is incurring news publication, employment issues, banks association and social media network. The company can rely on lobbying to help in administration of political matter and business operation, associate with public and bringing positive impact to social. Buy this way, Top Glove can reduce the risk in global business extension and minimize the possibility of legal fault. Top Glove should create own brands in the long term as it does not have own brand gloves. By creating its own blend of gloves helps Top glove to build brand images and secure customer loyalty by having products that carry its own brand name. The benefit of creating a own brand name would also include create brand recognition, an existing firm that has strong brand recognition will repel the new entrants and if the brand existing product is being perceived as unique would result in competitor need to spend more cash to promote and educate its customer about their product and directly increase the cost of taking over the market thus make the market unfavorable for new entrants (CIMB, 2007). Due to gigantic size of Top Glove Company, exponential growth and expansion could go against Top Gloves favor and makes it difficult to control and keep an eye on its foreign plants. Top Glove need to create a more centralized decision making environment which its foreign plants receive orders from its mother headquarters and enforce strict controls on the foreign plants to ensure illegal activities which is demonstrated by illegal labor issue once happened to top glove manufacturing plant at Klang that whooped to RM 11.4million would not happen in the future (ANIS, 2006). Top Glove should develop more unique technology to increase barrier of entry. currently Top Gloves latex manufacturing sector known to have a low entry barrier which is only from around 1 million to 1.5 million to open a new production line. It is considered low barrier for competitor manufacturer to enter the industry. New players only need to keep on producing to enjoy the share of wealth from the market due to economic of scale. Aggressive expansion by big players pose a serious threat to Top Glove as they need to come out with something unique in order to distinguish themselves from the competitors. For example top glove can develop proprietary product technology, technology is an intangible asset that resembles a barrier to entry, if an existing product is protected by a patent, it would not be possible for the new entrant to use the same technology to create the product without the permission from the patent owner (TomSpencer, 2010). Top-Glove needs to protect their intellectual property right from violation in Indonesia. Of Protection of intellectual property rights (IPR), Indonesia is hindered by inadequate enforcement of the relevant rules and regulations. Problem in intellectual property rights protection raised by industry include rampant audio, software, and video disk piracies (with a piracy rate estimated at 87 percent); the high percentage of piracy will affect the revenue of Top-Glove in Indonesias market. So a strong professional team must be created to strengthen and find ways to protect the intellectual property in Indonesia to create a high competitiveness or more values company in the Indonesia. Top Glove Company should be vigilant and creative in building strategies to protect their products from infringement. As an example, a company might first identify the counterfeiters of its product. They then proceed to negotiate and try to develop them as legal licensees of it products. Several general principles are important for effective management of intellectual property rights in Indonesia. First, it is important to have an overall strategy to protect your company IP. Second, company IP is protected differently in Indonesia than in the other country. Third, right must be registered and enforced in Indonesia under their local laws. Registration of patents and trademark is on a first-in-time, first-in-right-basis, so Top Glove should apply for trademark and patent protection even before selling their products or services in the Indonesia market. It is the responsibility of rights holder to register, protect, and enforce their right. Company may wish to seek advice from local attorneys or IP consultants who are experts in Indonesia law. It is important of strengthen and protect the intellectual property before entering a new entry market. It will bring the company a lot of economic benefit for their business and prevents other parties from using and taking the be nefit of the result of their creative and innovative mind without their concern (Purba, 2001 Sommeng, 2002). 4.0 Conclusion When we try to expand to others countries, it is important for us to analyze the countrys environment factors. The environmental factors consist of their political legal, economic competitiveness, social cultural, technology and local competitor. Then the company needs to know how much benefit they can gain from the expansion strategy that they use versus the risk that they assume in order to implement the expansion strategy to another country. By knowing this, the company will have better chance of succeeding in the new market. Top Gloves is currently facing some problems which are the increase of labor cost, high initial investment, lack of educated people and ecology. It is estimated that glove prices will increase by 3-5 percent result of the increase in the labor cost according to the categories of the product. Initially, Top Glove also need to invest heavily when first expand the market into Indonesia. In addition, lack of skills and technique workers in Indonesia will slow down the operation in producing the product. On top of that, plantation is also another issue result of the changes of climate. Throughout the analysis, we found out that Top Gloves using the wholly owned subsidiary and exporting as its expansion strategy. In order to compete, Top Glove needs to use exporting strategies because the local market is not big enough to support the growth of the company. Top Glove had owned large percent of the global latex market besides from few competitors in other countries. Besides that, in our assignment, we also had recommended some expansion strategies which will work out on Top Glove Company in Indonesia. These includes the expansion of their production line in rubber rich country of Indonesia. However, there is little aspect which Top Glove had to concern when they need to enter into new market which is political aspect, the countrys economy perspective, IP protection and so on. All these aspect will directly influence the brand image of Top Glove and also ROI to the company. Foreign country expansion and exporting strategy will help the company to reduce the risk. If there is a problem in a country, the company still can survive because they have wholly owned subsidiaries in other countries. My having wholly owned subsidiaries in other countries, the company can better manage their operation and strategy implementation. So in overall, we think that the company should enter Indonesia market. The benefit bought by the expansion outweighs the risk to the company. We predicted the company will continue to flourish under the new expansion into Indonesia. Hopefully, the expansion will pave a way for the company to be more competitive and able to maximize their shareholders wealth.

Brief Shoe Horn Sonata Essay

A wise man once said, â€Å"In the end we will remember not the words of our enemies but the silence of our friends†. Two women who go through horrific scenes of war and ill treatment of the Japanese but their friendship is what gives them purpose, comfort and strength to carry on. Though after fifty years of the War and of being separated they have no ill feelings toward the Japs but are emotionally torn by their separation. This is the story of The Shoe Horn Sonata. The Shoe-Horn Sonata is characterised by having a two act structure, two main time frames, two settings and two main characters. The two sets are: the television studio and the motel room. These are visually presented depersonalised and simple, allowing theatrical flexibility. The interplay of dialogue, music, sound effects and projected images work together to create wartime setting and an extra emotional dimension to the play. The audience’s proximity to the stage enhances the intimacy created by the bareness of the stage and the re-connection of the two main characters: Bridie an Australian Army Nurse & Sheila a British Civilian. The broad emotional feel of the play is embedded in the dialogue of the script that uses idiomatic expression and juxtaposition to individualise the characters personalities and backgrounds. Descriptive Language is used to recapture the past, exposing fears, secrets and hopes. Humour is also used to soften some of the horrors of the past. The conversational tone of the interview sessions add explicit detail while establishing the creditability of the witnesses. Music complements the visual action of the text. The lyrics of songs and the chosen music illuminates multiple interpretations of ‘sonata’ within the play in that the music often functions to relay historical events and the more personal story of Bridie and Sheila. Even when the numbers in their choir decimated they continued for they thought it was up to them to carry on. We sang our sonata whenever we could so the camp would know there was still music left†. Music therefore became pivotal to their survival, a symbol of willpower and determination. This is seen in Act One, Scene 3 with the singing of ‘Jerusalem’. It highlights the historical context of the scene and it is also sung by Bridie and Sheila to help them get through their ordeal of waiting in the water when their ship had been sunk. These projected images reinforce the historical accuracy of what is being said. It allows the audience to visualise not only the action between the two main protagonists but also of the projected images. These images juxtapose and resonate deeply within the responder. These images are a background to the dialogue and show a glimpse in the past containing photographs of ships burning in Singapore Harbour, the Japanese invasion and the malnutrition of prisoners at war. They effectively communicate information and ideas as well as linking the past to the present. Light is another among the many other visual devices used in the play to help develop themes and characters. It is used simply and effectively to create atmosphere within the text, as well as to draw attention to the characters. This is done through the interplay of light and dark, via spotlighting, blackouts and fade outs. When Bridie and Sheila are emotionally separated they are often lit separately, whereas once reconciled by the end of the play, they are lit in partnership. This also highlights the power of the theme friendship in the play. As they dance, the lights gradually fade while the spotlight shines on the shoe horn. This visually indicates its symbolic importance, as an object that brought them together, forced them apart and then in the end reunited them. Therefore it is evident through the various effective visual and literary techniques, that this distinctively visual texts convey distinctive experiences and therefore change the way we view visual elements and our perception of them.

Analyzing Aristotle Essay

The soul and the body are different forms. While the body is visible and mortal, the soul is invisible and immortal. He suggests that although the body dies and decays, the soul continues to exist. I do believe there is life after death, everyone must eventually die, and it cannot be avoided. However, even though death is a fact of life, it is a topic that many people prefer not to talk about. This avoidance of discussion is usually due to the denial of one’s own death and the denial is usually due to fear. The fear is, for many people, a fear of the unknown. In my opinion i believe that when humans die, the body and the brain dies, but the mind still exists and it creates our afterlife according to our own beliefs and expectations. If a person believes there in nothing after death then there will not be a dream, it will be as if the person is asleep forever without dreaming. 2) Yes, I agree that the universe is purposeful. The purpose of the creation, every though you have is creating your tomorrow. The universe has mysterious ways of revolving what we do day by day. For example Karma: The sum of a person’s actions in this and previous states of existence, viewed as deciding their fate in life. – Aristotle said: â€Å"Yet there is God, though not perhaps the simple and human god conceived by the forgivable anthropomorphism of the adolescent mind. † Aristotle represents God as self-conscious spirit. A rather mysterious spirit; for Aristotle God’s never does anything; he has no desires, no will, no purpose; he is activity so pure that he never acts. He is absolutely perfect; therefore cannot desire anything; therefore He does nothing. His only occupation is to contemplate the essence of things; and since He himself is the essence of all things, the form of all forms, his sole employment is the contemplation of himself.

Cleveland Institute of Music Admissions Costs and More

Family Is The Head Of Our Family - 1377 Words

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Lifespan Psychology - 4621 Words

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Legal Aspects of Property Law for Paul and Rose-myassignmenthelp

Question: Write about theLegal Aspects of Property Law for Paul and Rose. Answer: Introduction Land laws are the laws of land which are related to the rights of usage, exclusion and alienation of the other person from land (Stroud, 2013). The land laws history of England are applicable on the Singapore land laws, and these can be traced back to the Romans, and even to rule of Saxon monarchs which was the Dark Age. The reason for this is that most of the history of human beings deems the land as being a source of their private wealth. The English Court of Chancery led to the development of this body of law, which is deemed as equity and this can be seen as being concurrent o the common law in the present age (Hudson, 2013). Court of Chancery had a key role of enforcing the usage and the role of this could not be accommodated through a stringent framework of the laws of land. And owing to this role, there was a differentiation drawn through the legal interests and the equitable interests (Moffat, Bean Probert, 2009). And when it comes it the land laws, the registration of land is deemed as a crucial aspect of it. And this land registration system is based on three key principles, i.e., insurance, curtain and mirror (Ford, 2015). In the following parts, the different aspects of these concepts have been discussed with reference to the given case study. Issue The key issue in this case has George as the plaintiff and Paul as the defendant. And the case revolves around the legal rights which George can claim regarding the house which had been purchased by Paul and Rose. The rights relate to whether George can be evicted in a successful manner by Paul, or not. The creation of express trust of George would be deemed as the key factor which influences the claims made by Paul for evicting him from the house. Rule The co-ownership in the equity is deemed as tenancy or the joint tenancy commonly. It is crucial to show the manner in which the ownership is held and where it is a tenancy in common, it becomes crucial to determine the proportion of shareholding which is held by each of the tenants. The extent of the entitlement with regards to the declaration of trust can be freely determined in the express trusts (Liew, 2017). This results in the implications being overridden by the facts, the proportion of the contribution. However, where there is no express trust, for instance in such a case where the trust had been created through a constructive trust or the parties fail to provide the extent of ownership of conveyance, the beneficial entitlement is simply assumed under the law through the conduct of the people (E-Law Resources, 2017a). In Stack v Dowden [2007] 2 AC 432, Dowden and Stack co-habited the house and purchased in their joint name. However, no declaration had been made with regards to the beneficial interests entitlement (Gravells, 2013). The purchasing price of the property came from the savings and sale of property of Dowden. And the remaining was obtained through a mortgage. Upon the separation of parties, a sale of property and equal distribution of proceeds was sought by Stack. The court held that as the legal title had been held jointly, the beneficial interest had to be held jointly and this presumption could only be displaced in case the evidence was shown that this was not the intention of the parties (E-Law Resources, 2017b). A trust denotes the fiduciary relationship amidst parties in which the beneficiary interest of the beneficiary is protected for the land or property which is given to another party, i.e., the trustee (E-Law Resources, 2017b). Gissing v Gissing [1971] AC 881 provides that where there is an absence of declaration of the trust, the constructive trusts have to be applied particularly when there has been an inducement of trustee where the person acts in their detriment by believing the other. In such a case, such person would deem to hold a beneficiary interest in the land (Clarke Greer, 2016). Eves v Eves [1975] 1 WLR 1338 was a case where the house was brought in the name of the defendant but the same was not contributed directly by the plaintiff. Due to these reasons, applying constructive tryst, the claimant was allowed to obtain one quarter of the beneficial interest (Sexton Bogusz, 2015). The proprietary estoppel is something which helps in creating the proprietary interest in a property or a land, particularly where there is an absence of the standard or the proper formalities. The operations of this is based on the unconscionable behaviour which is used to award the interest in the land, as being a remedy, particularly when the entitlement is denied to the claimant as the legal title has to be deemed as unconscionable (Wilken Ghaly, 2012). In Jennings v Rice [2002] EWCA Civ 159, the plaintiff used to look after the defendant and this continued till the death of the defendant. The plaintiff was never paid anything and was instead promised the house with the furniture. This led to the plaintiff being awarded 200,000 as the court held that giving a proportional judgement with regards to the expectations of the plaintiff had to be done and detriment had to be made. And the amount of 200,000 was deemed as the detriment calculation for the plaintiff (Ball, 2015). Application The rules discussed above now have to be applied to the give case study. Firstly, it has to be clarified that George was never named as the owner of the house. He was the owner of the flat which was later on sold. Hence there was no express trust in this case and instead there was a presence of constructive trust, i.e., something which is to be construed from the conduct of the parties. In this case, the conduct was such that George sold his flat to go and live with Rose and Paul and gave the proceeds from the sale of flat to Paul, which was partly used by Paul for repaying the mortgage of the house and partly for constructing the house. In return, the implied promise was for George to live in the house and be provided with care, food and shelter. And this even continued till Rose was alive. Only upon the death of Rose did Paul ask George to leave the house. These contributions of Paul particularly towards the mortgage of the money would be deemed as an indirect contribution towards the house, based on Eves v Eves and this would allow Paul to make a claim on the house, particularly to the portion of contributed mortgage and the constructed portion of the house. The conduct of Rose and Paul was very clear to depict to any reasonable person that he would be staying in their house and in return, he paid them the sale proceeds. Applying Stack v Dowden, the house was co-inhabited by the three even though there had been no declaration on the beneficial interest entitlement. The mortgage and the construction of house were carried on by money of George and so, the beneficial interest had to be distributed according to the contributions. Gissing v Gissing provides that in absence of declaration of the trust, the constructive trusts have to be applied, particularly owing to inducement. Here, George worked in his detriment and gave the entire money to Paul. Also, applying the principle of proprietary estoppel, there was an absence of standard formalities in the proprietary interest of the house. And there was an unconscionable behaviour and denying entitlement to George would be unconscionable. Applying Jennings v Rice, even though George never paid anything, he gave his life earnings to Paul due to the implied condition of him staying with Paul and Rose owing to his ill health. Hence, damages have to be awarded to George to the proportion of detriment. And based on the calculation of detriment of this case, there is a need to stop Paul from evicting George from the house as neither it is rightful, not justified. Conclusion Hence, in this case, it becomes very clear that the conduct of the parties was such which denoted the presence of constructive trust and based on the application of the different case laws, it becomes clear that George cannot be evicted by Paul. And if the same is considered, there is a need to pay damages to George as a detriment was caused to him when he paid the proceeds of flat to Paul, and owing to the unconscionable behaviour, denying entitlement to George would be unconscionable. In short, George cannot be evicted from the house due to his contributions. Issue The key issue in this case is the changed position where it is deemed that the house was conveyed in name of Paul and Rose as being tenants in common and it was later on brought to the notice of the parties that Rose had named George as being the sole beneficiary to her property in the will. Rule Tenancy in common states that both the owners have the share in the property and this share is undivided, which means that the co-owners are entitled to occupy the entire property even when there share is very small (Watts, 2013). Also, there is no physical division of land and the possession is held in unity. The concept becomes relevant on the sale, or the death of the person or where the property is to be distributed. There is no operation of survivorship when it comes to tenants in common and each tenant can nominate to whom they will leave their share (Atkins, 2015). Goodman v Gallant [1986] Fam 106 was a case in which Goodman held half the beneficial interests in the matrimonial house. And the legal title was held by the husband. After her husband leaving the home five years later, Goodman got into a relationship with Gallant and he moved in the house. After two years, the negotiations were entered into with husband for his share of the house to be sold to Goodman. The price was set and the declaration of trust provided that the property was held as joint tenants. Goodman gave a notice later on for severing the joint tenancy and stated that she held 75% beneficial interest due to the fact that she already held 50% shares and had contributed in the purchase of the later half. The court however, held that the entitlement was to continue at 50% of the beneficial ownership. This was because the declaration of trust, in absence of mistake or fraud had to be taken as a conclusive aspect with regards to the ownership rights of the parties and the contr ibution of the parties was to be deemed as irrelevant (E-Law Resources, 2017c). Application In the given case study, if Rose and Paul are deemed as tenants in common. This would mean that upon the death of any of these two, they can state to whom their share of property would go. Applying Goodman v Gallant Rose could give the entitlement which she owed to George and not that of Paul and so, she could make her the sole beneficiary for her property. As the will of Rose provided that George had to be deemed as the sole beneficiary of her property, the express right over the property of George would disallow Peter from evicting George. As George would become an express beneficiary, instead of the same being required to be obtained from the conduct of the parties under constructive trust, Paul could not be evicted from the home. Conclusion On the basis of the application of the facts of the case study to the relevant rules, Paul cannot evict George even in this case as he had explicitly been made the beneficiary of the property by the will of Rose. References Atkins, S. (2015). Equity and Trusts (2nd ed.). Oxon: Routledge. Ball, J. (2015). Jennings v Rice [2002]. Retrieved from: https://webstroke.co.uk/law/cases/jennings-v-rice-2002 Clarke, S., Greer, S. (2016). Land Law Directions (5th ed.). Oxford: Oxford University Press. E-Law Resources. (2017a). Co-ownership. Retrieved from: https://e-lawresources.co.uk/Land/Co-ownership.php E-Law Resources. (2017b). Stack v Dowden [2007] 2 AC 432 House of Lords. Retrieved from: https://e-lawresources.co.uk/Land/Stack-v-Dowden.php E-Law Resources. (2017c). Goodman v Gallant [1986] Fam 106 Court of Appeal. Retrieved from: https://e-lawresources.co.uk/Land/Goodman-v-Gallant.php Ford, R.O. (2015). The Parables of Christ. Indiana: Xlibris Corporation. Gravells, N. (2013). Landmark Cases in Land Law. Portland: Hart Publishing. Hudson, A. (2013). Equity Trusts (3rd ed.). London: Cavendish Publishing Limited. Liew, Y.K. (2017). Rationalising Constructive Trusts. Portland: Hart Publishing. Moffat, G., Bean, G., Probert, R. (2009). Trusts Law: Text and Materials (5th ed.). Cambridge: Cambridge University Press. Sexton, R., Bogusz, B. (2015). Complete Land Law: Text, Cases, and Materials (4th ed.). Oxford: Oxford University Press. Stroud, A. (2013). Making Sense of Land Law (4th ed.). Hampshire: Palgrave Macmillan. Watts, G. (2013). Todd Watt's Cases and Materials on Equity and Trusts (9th ed.). Oxford: Oxford University Press. Wilken, S., Ghaly, K. (2012). The Law of Waiver, Variation and Estoppel (2nd ed.). Oxford: Oxford University Press.