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Penalty kicks often play a decisive role in the most prestigious international football tournaments. The present study investigated whether shooting performance of the penalty kick in football would be improved by providing specific attentional and motivational instructions. Twenty-four experienced male volunteers were asked to kick a ball at one of four targets located in a regulation-sized goal. Using a goalkeeper-independent strategy, subjects performed the penalty kicks under external focus (EF; targets in the goal), autonomy support (AS; choice of target order), combining external focus and autonomy support (EF/AS), and control conditions (C). A goalkeeper tried to save the ball during each attempt. The mean number of scored goals and kicking accuracy of goal scored were used to determine penalty kick performance. The EF/AS combination enhanced the number of goals scored compared to the C condition. No other significant differences were observed between the conditions in the number of goals scored. The EF/AS group displayed greater kicking accuracy of goals scored relative to the AS and C conditions. Also, the kicking accuracy of the EF condition was significantly better than the C condition. Additionally, the results demonstrated that the EF/AS condition resulted in fewer missed shots compared to the C condition. There were no significant differences in blocked shots between the conditions. The findings suggest that promoting an external focus of attention and autonomy support collectively may enhance penalty kick performance.

The COVID-19 pandemic has presented many issues for courts, often requiring immediate consideration and swift delivery of reasons Nevertheless, experience has taught us that, in times of crisis, heightened vigilance must be afforded to the protection of individual rights Two judgments delivered at the peak of the pandemic illuminate the fragility of rights in the face of wider societal concerns Both cases contain statements of purported principle which are legally dubious and, if left unqualified, have the potential to fundamentally dilute the protections afforded by the European Convention on Human Rights © 2020 Thomson Reuters and Contributors

THE appeal in R. (on the application of SG) (previously JS) v Secretary of State for Work and Pensions (Child Poverty Action Group and another intervening) [2015] UKSC 16 concerned a challenge to the cap on welfare benefits, one of the measures introduced as part of the Government's austerity-driven economic and social policy. The “benefit cap” operates to limit the amount of welfare benefits that can be received by non-working households, to the equivalent net median earnings of a working household. The Welfare Reform Act 2012 contains provisions allowing the Secretary of State to make regulations providing for a “benefit cap” scheme. It is implemented through the Benefit Cap (Housing Benefit) Regulations 2012 and operates by a reduction in housing benefit once a specified maximum amount is reached. Benefits covered by the cap include housing benefit, child benefit, and child tax credit. Once the cap is reached, no account is taken of the number of children in the family. The lawfulness of the Act itself was not challenged. The appellants’ argument was that the implementation of the scheme was discriminatory and contrary to the Human Rights Act 1998.

Private organizations are deeply entrenched in fulfi lling the responsibilities of government through the provision of public services. In this context, we must question the conceptual coherence of drawing sharp distinctions between public and private functions. In YL v Birmingham City Council, however, the House of Lords had to determine which of the various functions contracted out by public authorities retain their public character for the purposes of the United Kingdom’s Human Rights Act 1998. This article analyzes the complex public/private division set up by the Human Rights Act and argues that the decision of the House of Lords has led to a gap in human rights protection and has weakened public accountability. Public functions and services traditionally carried out by public entities have been transferred increasingly to the private sector. 1 In the United Kingdom, policies such as privatization, outsourcing, and public/private projects under the Private Finance Initiative 2 have altered dramatically the way in which public services are delivered. Although these policies cover a variety of activities and varying arrangements, they typically share three features: the transfer of public functions, with the associated delivery risk, to private entities; the use of market-style competition to select the supplier; and a shift in the measurement of performance — from a concern with process to the achievements of outputs. “ Internal markets ” have been introduced into the provision of such fundamental public services as health and education, organized around a separation between “ purchasers ” and “ providers ” and governed by sophisticated commercial contracts. 3 Prisons and immigration centers are managed by

only against public authorities.2 The issue of whether a body is a public authority has proved highly controversial. The hiving-off of many traditional governmental functions through policies such as privatisation, outsourcing and projects under the Private Finanace Initiative (PFI) has led to a blurring of the traditionally understood publicprivate distinction.3 The changed nature in the way that public services are delivered has led to sharply divergent views among the judiciary about which functions are those of a public nature for the purposes of the Human Rights Act. This is evident in the YL judgment itself: a split decision, with two dissenting judgements.4 The division in the House reflects different understandings of the operation of the Human Rights Act, the public-private distinction and, perhaps more fundamentally, competing ideological stances. The decision also suggests that the ghost of Dicey still haunts the development of public law in our legal tradition. Dicey's premise that the Rule of Law admits of no separation between public and private law and that all people were subject to the ordinary laws of the realm inhibited the development of public law.5 The first inkling of change occurred during the 1960's.6 Influenced no doubt by EC and human rights law, gradually the judiciary began to establish substantive public law rules and principles. It is ironic that just as public law became more established and effective in the control of government power, the state began to shrink and the pattern of government to change. The transformation of the delivery of public services poses a serious threat to public law values, to ensuring public accountability and to the

THE right not to be subjected to torture or to inhuman or degrading treatment or punishment is guaranteed in absolute terms in Article 3 of the ECHR. This article imposes on a State both a negative and a positive obligation. In recent months, the House of Lords has considered cases raising both obligations pursuant to Article 3. This paper will examine first the nature of Article 3 and these obligations, second the jurisprudence of the European Court of Human Rights on the issue of State responsibility, and finally the recent decisions of the House of Lords in R. (on the application of Adam, Limbuela and Tesema) v. Secretary of State for the Home Department

The dramatic terrorist attacks in the United States in September 2001 all too clearly illustrated the threat posed by international terrorism. Understandably, politicians are provoked into taking tough measures to protect their citizens from terrorist enemies. In times of danger the civil liberties implications of such measures can easily play second fiddle to security needs. Indeed, we need look no further in our jurisprudence than the discredited majority decision in Liversidge v. Anderson [1942] A.C. 206. Recently, Lord Woolf has warned that “the mistakes which have been made in the past, in relation to internment of aliens at the outbreak of war, should not be forgotten” (A v. Secretary of State for the Home Department [2002] EWCA Civ 1502 at para. [9]).

In R. (Bancoult) v. Secretary of State for Foreign and Commonwealth Affairs [2001] 2 W.L.R. 1219 a former resident of the British Indian Ocean Territory (“BIOT”) successfully challenged the lawfulness of banishment from his own country.

The Labour government has quickly acted on its election promise to introduce a bill of rights into domestic law. The Human Rights Act 1998 partially incorporates the European Convention on Human Rights (ECHR) into United Kingdom law. This legislation is part of a wider constitutional package including devolved government for Scotland and Wales and reform of the House of Lords. The government’s programme is intended to modernise and indeed transform the British constitutional structure. According to the government, the Human Rights Act will bring rights home. Individuals will be able to argue for their Convention rights in the United Kingdom’s own courts and tribunals and judges will be able to adjudicate directly on Convention issues. All new laws will be carefully scrutinised to ensure compatibility with Convention rights.

Although those sentenced to life imprisonment have no right to release, a life sentence rarely involves imprisonment for the remainder of a convicted offender's natural life. Life prisoners may hope for early release on the so-called “life-licence”, whereby they remain liable to be recalled to prison for the rest of their lives.