In this case the precedent Cook v Cook [1986] HCA 73was discussed and dissented from (Bant 2015). Bant, E., 2015. | All rights reserved. Trade practices Unconscionable conduct Gambling transactions Section 51AA for the Trade Practices Act 1974 (Cth) Whether gambling transactions involved a contravention of s 51AA of the Trade Practices Act. for your referencing. This is a narrow conception of what amounts to unconscionable conduct, ruling out cases where a trader neglects to take reasonable steps that would alert it to the vulnerability of the customers with whom it is dealing. In judging the evidentiary value of various precedents the case of Imbree v McNeilly [2008] HCA 40 must be considered (Ben-Yishai 2015). The Court also emphasised that the essence of the doctrine of unconscionable conduct is not to relieve parties against improvident or foolish transactions but to prevent victimisation. This meant that the court was bound to consider the precedential value of such a case but was not bound to follow the previous position of law in the matter. Carlton 3053 VIC Australia Lexisnexis Study Guide New Torts Copy - uniport.edu This type of unconscionable conduct, results into dealings those are in general oppressive and harsh towards the weaker party (Burdon, 2018). The following paragraphs will elaborate on the judicial interpretation of this doctrine as it was presented in this case. Earn back the money you have spent on the downloaded sample by uploading a unique assignment/study material/research material you have. Kakavas v Crown Melbourne Ltd & Ors [2013] HCA 25 is a landmark Australian judgment of the High Court. My Assignment Help (2021) BU206 Business Law [Online]. The Court dismissed the place for constructive knowledge in cases of this kind. Harry Kakavas had a chequered past and a serious gambling problem. ; Philippens H.M.M.G. The Court highlighted that Kakavis did not present himself as someone incapable of making worthwhile decisions for himself. Equity comes into play when in contract, one party exercises dominance and advantage, over other party which has a special disadvantage or disability like old age, illness, lack of, education, illiteracy or any other similar type of factors. Result. to receive critical updates and urgent messages ! He claimed that Crown had taken advantage of his addiction, which he alleged to be a special disability, for its financial gain. Generous discounts and affordable rates define us. University Square *The content must not be available online or in our existing Database to qualify as The court specifically stated that it was telling that there was no decided case that the doctrine in Amadio has successfully been applied by a plaintiff complaining of loss suffered on account of multiple transactions conducted over many months with a putative predator [22]. Critical Analysis of Kakavas v Crown Melbourne Ltd Gambler lucks out in the High Court of Australia - Lexology Kakavas v Crown Melbourne Ltd - Wikiwand Legislative procedures are amended and scrutinized so that accurate provisions of law can be formulated so that the rights of all parties in a particular scenario are well represented however in the present scenario of Australias legal framework such a duty of care is not provided for. . He also submitted that Crown had constructive notice of his special disadvantage [150]. Kakavas v Crown Melbourne Ltd [2013] HCA 25. In 1996, mental health professionals diagnosed him as suffering from a pathological gambling condition. In 1998, Kakavas was the subject of a withdrawal of licence order where Crown chose to exclude him from the premises on the basis of pending armed robbery charges. [See J M Paterson, Knowledge and Neglect in Asset Based Lending: When is it Unconscionable or Unjust to Lend to a Borrower Who Cannot Repay (2009) 20 Journal of Banking and Finance Law and Practice 1]. The Problem Gambler Thus, the rights of the parties in case of such a position of law would be completely dependent on the legal stand of previous decisions. My Assignment Help. BU206 Business Law | Kakavas v Crown Melbourne Ltd Case Study Access to gambling has been a hot topic in society and the media in recent times. Kakavas claimed that the Crown hadexploited his gambling problem so that he became a regular visitor and alsoby unconscientiously allowing and encouraging Kakavas to gamble at Crown while the knew or ought to have known that Kakavas would be required to forfeit winnings by virtue of a NSW exclusion order. Although the substantive sections, which He The provision undersection 51AA is a question of fact to be decided in line with the special circumstances of thecase. This case clarified that a cab driver would have to observe a duty of care towards his passengers. An influential aspect was that gamblingwas naturally a risky transaction for both parties involved because the very aim of the game is tocause financial loss to the rival party. the matter related to claims that Skip to document Ask an Expert Sign inRegister Sign inRegister Home Ask an ExpertNew influence. Kakavas submitted, at [6], that the principles of Amadio applied, particularly that ..whenever one party by reason of some condition or circumstance is placed at a special disadvantage vis--vis another and unfair or unconscientious advantage is then taken of the opportunity thereby created. The disability affects his or her ability to look after his or her own best interests in his or her everydaylife and not just in regard to the transaction with thewrongdoer; and? At some point, the Appellant was charged and convicted of fraud, which he alleged to have committed so as to fund his gambling behaviors. [2] . After serving his sentence, the Appellant negotiated with Crown to readmit him back to the casino, which was allowed and he was allowed to be going to the casino. It is particularly difficult to overrule constitutional precedents as the courts are conferred their powers through the constitution and thus the same needs to be interpreted in the same light. The judicial system and its framework is based on the hierarchy of courts and this hierarchy thus in effect dictates that lower courts would be bound by the decision of higher courts (Groppi and Ponthoreau 2013). Powered bySymatech Labs Ltd, NIEZGODA AND MURRAY EXCAVATING TERMS AND CONDITIONS, NO-DEFAMATION AGREEMENT By contracting our services and, CONVENTION HOUSING EXPERT 24TH FEBRUARY 2022 15, ASSIGNMENT OF INTELLECTUAL PROPERTY RIGHTS The Parties. Concordia L. However, responsibilities to take care when dealing with potentially vulnerable consumers may be imposed underss 2122 of the Australian Consumer Law, which contains broad prohibitions on unconscionable conduct that go beyond the equitable doctrine discussed in Kakavas, and under the Contracts Review Act 1980 (NSW) which contains a wide ranging power for courts to reopen unjust contracts. Reg No: HE415945, Copyright 2023 MyAssignmenthelp.com. australiancontractlaw/cases/bridgewater.html, Copyright 2023 StudeerSnel B.V., Keizersgracht 424, 1016 GC Amsterdam, KVK: 56829787, BTW: NL852321363B01, Kakavas v Crown Melbourne Ltd & Ors [2013] HCA. A Ratio decidendicannot be dissented from unless rule of law and due process warrants the same (Saunders and Stone 2014). We guarantee you premium quality services. In 1995, he sought and was granted a self-exclusion order from Crown. Retrieved from https://myassignmenthelp.com/free-samples/bu206-business-law/kakavas-v-crown-melbourne.html. Kakavas v. Crown Melbourne LTD; Still Curbing Unconscionability: Kakavas in the High Court of Australia. Well, don't you worry about it for we have you covered. The Court explained that actual knowledge of the special disability was central to the finding of victimisation necessary to establish unconscionable conduct in equity. Lamond, G., 2014. The High Court took the opportunity to clarify and tighten the principles associated with Amadio type claims. Kakavas was seeking to set aside his decision to gamble $20 million with the result that the money he had gambled would be returned to him. The case of Kakavas V Crown Melbourne Limited (Acn 006 973 262) & Ors [2013] Hca 25is particularly important as it elaborates on a lower court authority to dissent from a precedent delivered by superior court while also curbing the powers of the lower courts to act arbitrarily and in a discretionary manner by prescribing the importance of a Ratio decidendi. An Australian august corpus: Why there is only one common law in Australia. Rev.,27, p.27. When seeking equitable intervention their Honours stated the following: The Court regarded it as highly relevant that the activities took place in a commercial context in which ..the unmistakable purpose of each party was to inflict loss upon the other party to the transaction and that there was nothing surreptitious about Crowns conduct [25]. Course. Please upload all relevant files for quick & complete assistance. unconscionable conduct | Opinions on High - University of Melbourne What is the ratio and obiter of Kakavas v Crown Melbourne Limited . His research interests include commercial transactions and gaming regulation, stemming from taking Contracts with Dr Jeannie Paterson and previously working in betting regulation for Racing Victoria Ltd. Melbourne Law School Is it late at night but you need some urgent assignments finished, straight away? Knowledge for the purpose of unconscionable conduct meant actual knowledge or at least wilful ignorance (where a trader closes its eyes to the vulnerability of a customer). He was also what is known in the industry as a 'high roller'. Kozel, R.J., 2017. Login | RSS, Kakavas v Crown Melbourne Limited [2013] HCA 25 (5 June 2013): High court reviews the principle of unconscionable conduct, the operation of equity and the nature of special disadvantage, Kakavas v Crown Melbourne Limited [2013] HCA 25, that Kakavas abnormally strong urge to gamble was not a compulsion which deprived him of the ability to make a worthwhile choice whether or not to gamble, or to continue to gamble, with Crown or anyone else, Crowns employees did not knowingly exploit the appellants abnormal interest in gambling. Kakavas v Crown Melbourne Ltd case note - StuDocu Rather the trader is said to have constructive knowledge of special disadvantage if she would have known of the special disadvantage had she made reasonable inquiries into the matter. In addition, neither our website nor any of its affiliates and/or partners shall be liable for any unethical, inappropriate, illegal, or otherwise wrongful use of the Products and/or other written material received from the Website. 185 Pelham Street Upload your requirements and see your grades improving. As explained by Justice Mason in Commercial Bank of Australia Ltd v Amadio [1983] HCA 14, the equitable doctrine of unconscionable dealing will set aside a transaction: whenever one party by reason of some condition or circumstance is placed at a special disadvantage vis--vis another and unfair or unconscientious advantage is then taken of the opportunity thereby created. Settled Versus Right: A Theory of Precedent. Case note 2 - Criminal law assignment - LAWS106 - StuDocu The trial Judge dismissed the Appellants claim against Crown, reasoning that even though the Appellant was a pathological gambler, he had not demonstrated how his condition hindered him from controlling his urge to gamble, and as such, he voluntarily decided to engage in gambling. James Ryan is a second year JD student at Melbourne Law School, and holds a BA in politics and history from Deakin University. Aggrieved by the findings of the trial Court, the Appellant filed an appeal to the Victorian Court of Appeal. However, thecourt unanimously rejected the argument by Kakavas that the Crown should be deemed to havereceived notice if it had investigated as a reasonable man would have done in the situation. When it comes to submitting the finished essays, we are never late. Phone: +61 3 8344 4475 Before the Court of the First instance, the Appellants main claim was that Crown, its then and former Chief Operating Officers had acted negligently at common law, had acted unconscionably and breach their statutory duties under the Victorian Casino Control Act. Allow us to show you how we can offer you the best and cheap essay writing service and essay review service. [1] Between June 2005 and August 2006, he lost a total of $20.5 million playing baccarat at a Melbourne casino operated by Crown Melbourne Ltd ('Crown'). recommend. equity, in which the High Court held that unconscionable dealing due to a lack of knowledge Harry Kakavas was a problem gambler who, in period between 2005 and 2006, lost $20 million dollars at the Crown Casino in Melbourne. Critical Analysis of Kakavas v Crown Melbourne Ltd [2013] HCA 25 (5 June 2013) (High Court of Australia): Issue: The issue involved in the present case study is whether Crown was involved in unconscionable conduct. Harry Kakavas had a chequered past and a serious gambling problem. The Crown had offered Kakavas free accommodation, use of the private jet, food & beverage deals and gambling rebates. Thus in cases of lower courts, this power to overrule judicial precedents does not arise if the judgment was given by a superior court. He claimed that Crown had taken advantage of his addiction, which he alleged to be a special disability, for its financial gain. This in effect states that a particular position of law that is settled by a high court cannot be overruled by a lower court and this lower court would be bound to give effect to this position of law. paper instructions. First, the Appellant argued that although previous Courts acknowledged that he was suffering from a pathological gambling condition, they proceeded to make a finding that he did not have a special disability that would lead to unconscionable conduct on the Respondents part. theNSW Supreme Court had no jurisdiction to order a punitive monetary award for breach The court was also guided by the assessment of the primary judge thatKakavas was a natural salesman and negotiator that was robust and confident. View sample3-Kakavas v Crown Melbourne Ltd.docx from KJKJK 000 at Australian Catholic University. Because of this, many casinos sought him out with incentives.Kakavas also used to cease gambling on several occasions when he visited Crown so that hecould entertain guests. The rationale of the principle is to ensure that it is fair, just and reasonable for the stronger party to retain the benefit of the impugned transaction, A court of equity looks at every connected circumstance that ought to influence its determination of the real justice of the case, proof of the interplay of a dominant and subordinate position in a personal relationship depends, in large part, on inferences drawn from other facts and on an assessment of the character of each of the parties., the concept of constructive notice does not apply to the principles enunciated in Amadio, the extent of the knowledge of the disability of the plaintiff which must be possessed by the defendant is an aspect of the question whether the plaintiff has been victimised by the defendant, Equitable intervention to deprive a party of the benefit of its bargain on the basis that it was procured by unfair exploitation of the weakness of the other party requires proof of a predatory state of mind. Bigwood, R., 2013. Their Honours confirmed that an assessment of unconscionable conduct calls for a precise examination of facts, scrutiny of relations and a consideration of the mental capacities, processes and idiosyncrasies of the parties. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. Kakavas v Crown Melbourne Ltd & Ors [2013] HCA 25 is a landmark Australian judgment of the High Court. He was also what is known in the industry as a 'high roller'. He later revoked the self-exclusion order. INFS3059 Project Management And Information Systems, MGMT2726 Business Ethics And Sustainability, LHA1004H Research Literacy In Educational Leadership And Policy, ECO600 Economics And Finance For Business, NSG2NCI Nursing Patients With Chronic Illness, NCS1102 Professional Conduct And Communication, FINS5512 Financial Markets And Institutes, HLTH 601 Critical Analysis Of A Health Issue, BMA609 Sales Management And Personal Selling, MGMT20144 Management And Business Context, 3231THS Managing Hosp Service Experiences, HA1022 Principals Of Financial Markets Group Assignment, PUBH6150 Quality And Safety In Health Care, HDS106 Diversity, Disability And Social Inclusion, ISY3001 E-Business Fundamentals And Systems, MBA402 Governance, Ethics, And Sustainability, EPM5500 Fundamentals Of Project Management, HI5019 Strategic Information Systems For Business And Enterprise, BSBSMB404 Undertake Small Business Planning, RES850 Modified 10 Strategic Points Template, NSG2EHP Education In Health Professional Practice, CH6059 Advanced Physical Chemistry Coursework, EDF6530 Introduction To Counselling Across The Lifespan, ECON6000 Economic Principles And Decision Making, ME503 Telecommunication System Engineering, ENG51001 Construction Site Safety And Risk Management, NUST10044 Critical Appraisal Of Qualitative Research, THT2114 Sustainable Operations And Destinations, ITECH7410 Software Engineering Methodologies, ITC105 Communication And Information Management, CP5520 Advanced Databases And Applications, HC2121 Comparative Business Ethics And Social Responsibility, BUACC5937 Information Systems Design And Development For Accountants, PROJMGNT 5004 Risk Assessment And Management, BMA314 Organisational Change And Development, ACCT20076 Foundation Of Management Accounting, COSC2473 Introduction To Computer Systems And Platform Technology. The Court did not accept that Kakavas pathological interest in gambling was a . Book Your Assignment at The Lowest Price Wang, V.B., 2018. These papers are intended to be used for research and reference An influential factor that was that gambling was by its very nature a risky transaction for both of the parties concerned. First, the High Court doubted that Kakavas suffered from a special disability in the sense required to make out unconscionable conduct. That's our welcome gift for first time visitors. The trial Judge dismissed the Appellants claim against Crown, reasoning that even though the Appellant was a pathological gambler, he had not demonstrated how his condition hindered him from controlling his urge to gamble, and as such, he voluntarily decided to engage in gambling. Kakavas claimed Crown engaged in unconscionable conduct. At age 27 he lost $110,000 of his fathers money at Crown Casino and in 1998, he spent four months in gaol for defrauding Esanda Finance Corporation of $286,000. This case thus effectively contributed to the development of legal stands within the Australian Commonwealth along with elaborating on the issue of duty of care (Groppi and Ponthoreau 2013). Unconscionable dealing is a concept based in equity and given statutory force under s 20 of the Australian Consumer Law (Cth) (previously s 51AA of the Trade Practices Act 1974 (Cth)). blackboard.qut.edu/bbcswebdav/pid-9418829-dt-content-rid- Kakavas v Crown Melbourne Ltd (2013) 250 CLR 392 August 30, 2019 Travis Facts Harry Kakavas was a problem gambler who, in period between 2005 and 2006, lost $20 million dollars at the Crown Casino in Melbourne. M.F.M. We have an array of choices when it comes to contacting us - live chat, email, or call. Date: 05 June 2013. The support you need will always be offered. Lower Court Judgment. This would also mean that such a decision would limit the scope of judicial authority in case of overruling precedents. The matter related to claims that the casino had taken unfair or unconscientious advantage of the opportunity created by a patron's special disadvantage, being a gambling problem.. Harry Kakavas - a known problem gambler who had a gambling turnover of $1.5 billion and losses of $20.5 . The full text is available here:http://eresources.hcourt.gov.au/downloadPdf/2013/HCA/25, -- Download Kakavas v Crown Melbourne Ltd (2013) 250 CLR 392 as PDF --, Kakavas v Crown Melbourne Ltd (2013) 250 CLR 392, Victorian Building Authority v Andriotis [2019] HCA 22, Jumbunna Coal Mine NL v Victorian Coal Miners Association (1908) 6 CLR 309, http://eresources.hcourt.gov.au/downloadPdf/2013/HCA/25, Download Kakavas v Crown Melbourne Ltd (2013) 250 CLR 392 as PDF. 'BU206 Business Law' (My Assignment Help, 2021) accessed 04 March 2023. HARRY KAKAVAS vs CROWN MELBOURNE LIMITED 1. Reasoning with previous decisions: beyond the doctrine of precedent. The allegations against Crown went to a full hearing before the trial Judge, at which point the Appellant adduced evidence to demonstrate that Crown had been inducing him to gamble at its Casino, despite having full knowledge of the Appellants addiction to gambling. Kakavas v Crown Melbourne Limited [2013] HCA 25 (5 June 2013): High Crown knew of Kakavas problems with gambling in the past but had subsequently been given a report by a psychologist which had indicated that Kakavas was now in control of his gambling. Sounds unbelievable, doesn't it? Name of student. It was not possible to consider the Kakavas special disadvantage separately, in isolation from the other circumstances of the impugned transactions which bear upon the principle invoked by him. The Court, in a joint judgement, upheld the decision of the primary judge stating "[i]n the absence of a relevant legislative provision, there is no general duty upon a casino to protect gamblers from themselves.. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Copyright 2008/2009 Peter A. Clarke All Rights Reserved. One suspects the likelihood of success will be increased by the presence of a somewhat more conventionally disadvantaged victim, whose vulnerability should be well apparent to the gaming venue. being a gambling problem. A self-exclusion order involves the gambler requesting the casino not to admit him to the premises for a period of time. The Court of Appeal, while affirming the trial Courts findings, dismissed the Appeal and held that the Appellant was not suffering any special disability as to lead to unconsented advantage by the Respondent. The judgment delivered by the High Court of Australia was purely based on the factual representation of the issue and the decision solely pertained to that. This nullifies the purpose of carriage of justice as uniformity is essential for observing equality before the law. The American Journal of Jurisprudence,59(1), pp.25-48. Thus, indifference, orinadvertence does not amount to exploitation or victimization. being set aside. Rev.,8, p.130. But these findings did not demonstrate that Kakavas was unable to control the urge to gamble. Heedlessness of, or indifference to, the best interests of the other party is not sufficient for this purpose. The Appellant, Harry Kakavas, according to the High Court of Australia, a "pathological gambler", who had a serious gambling problem for many years.In the period between June 2005 and August 2006, he spent a total of $20.5 million in playing baccarat at a casino located in Melbourne, which was owned and operated by the Respondent, Crown Melbourne From its very inception, the concepts of appeals and revisions have been provided to amend positions of law which do not meet the adequate standards in the interests of justice. identity in total confidence. This article related to Australian law is a stub. Appeal dismissed. Don't hesitate to contact us even if the deadline is within a few hours. Although theprimary judge established that Kakavas was a pathological gambler, the fact that he was able toself-exclude indicated that he could control his interests in a rational manner.The second issue that the court considered was whether the Crown was sufficiently awareof Kavasass alleged special disadvantage. (2021). AGLC3 Citation: Jeannie Marie Paterson and James Ryan, Casino Not Liable for Bets Made by Problem Gambler: Kakavas v Crown Melbourne Ltd onOpinions on High (6 August 2013) . Kakavas v Crown Melbourne Ltd Case Page Issues of gambling, the responsibilities of gaming venues and the regulation of problem gambling have been prominent in recent political debate. The American Journal of Comparative Law,61(1), pp.149-172. The issue as to special disadvantage must be considered as part of the broader question, which is whether the impugned transactions were procured by Crowns taking advantage of an inability on Kakavas part to make worthwhile decisions in his own interests, which inability was sufficiently evident to Crowns employees to render their conduct exploitative [124]. Books You don't have any books yet. Section 20 of the ACL provides restrictions on unconscionablity involved in by any, corporation. His game of choice was baccarat. Trusted by 2+ million users, 1000+ happy students everyday, You are reading a previewUpload your documents to download or Become a Desklib member to get accesss. What would be required for this decision to be overruled? A22 FOL 9 - Precedent.docx - Foundations of Law Module 9 Does the Northern Territory Supreme Court have to follow this decision? Only limited data is required as you place your order, all we need is your Kakavas v Crown Melbourne Ltd case note - Kakavas v Crown Melbourne Ltd [2013] HCA 25 (5 June 2013) - StuDocu Ask an Expert Sign in Register Sign in Register Home Ask an Expert New My Library Courses You don't have any courses yet. Nonetheless, the court acknowledged that in some circumstances, willful blindness. Now! In applying the Amadio principle, the Court emphasized the importance of the factual setting of each case. But he lost about 20.5, million dollar for which he claimed that the Crown Casino of Melbourne was involved in, unconscionable conduct (Fels and Lees 2018). The Appellants Appeal to the Australian High Court was premised on a number of grounds. Material Facts; The Appellant, Harry Kakavas, according to the High Court of Australia, a "pathological gambler", who had a serious gambling problem for many years. Heydon JAs decision was primarily based on the Callander, S. and Clark, T.S., 2017. The Courts reasoned that the Appellants condition did not take away his ability to decide and that the Appellant was capable of making rational decisions with regard to the relationship between him and the Respondent. This type of unconscionable conduct is not permitted by equity and also by statute. James Ryan is a JD candidate at Melbourne Law School. Kakavas v Crown Melbourne Ltd. Bond L. n this civil case, Mr. Kakavas was a serious gambler who gambled between July 2005 andAugust 2006. Aggrieved by the findings of the trial Court, the Appellant filed an appeal to the Victorian Court of Appeal. Only one step away from your solution of order no. The decision of the court, however, does not lock out actions by some * $5 to be used on order value more than $50. Kakavas v Crown Melbourne Ltd [2013] HCA 25. He then lost an appeal to the Full Court in 2012. The courtdecided that Kakavass pathological urge to gamble did not amount to a special disadvantage thatcould make him vulnerable to exploitation by the casino. In 2007, Kakavas instituted proceedings before the Supreme Court of Victoria to recover the $20 million he had gambled at Crown, but he was unsuccessful. At some point, the Appellant was charged and convicted of fraud, which he alleged to have committed so as to fund his gambling behaviors. Hutchinson, T., 2015. Kakavas was able to make rational decisions in his own interests, including deciding to refrain from gambling altogether at various intervals. ), Contract: Cases and Materials (Paterson; Jeannie Robertson; Andrew Duke), Company Accounting (Ken Leo; John Hoggett; John Sweeting; Jennie Radford), Financial Reporting (Janice Loftus; Ken J. Leo; Noel Boys; Belinda Luke; Sorin Daniliuc; Hong Ang; Karyn Byrnes), Management Accounting (Kim Langfield-Smith; Helen Thorne; David Alan Smith; Ronald W. Hilton), Lawyers' Professional Responsibility (Gino Dal Pont), Principles of Marketing (Philip Kotler; Gary Armstrong; Valerie Trifts; Peggy H. Cunningham), Financial Institutions, Instruments and Markets (Viney; Michael McGrath; Christopher Viney), Financial Accounting: an Integrated Approach (Ken Trotman; Michael Gibbins), Auditing (Robyn Moroney; Fiona Campbell; Jane Hamilton; Valerie Warren), Database Systems: Design Implementation and Management (Carlos Coronel; Steven Morris), Australian Financial Accounting (Craig Deegan), Culture and Psychology (Matsumoto; David Matsumoto; Linda Juang), Il potere dei conflitti.
Washington State Tab Renewal Grace Period 2021, Sun Gazing Meditation, Articles K