Methods of Lipid Analysis in Food

Methods of Lipid Analysis in Food Lipids are defined as the biomolecules whose solubility in water is less than that in non-polar solvents. This definition puts structurally distinct classes of compounds such as fatty acids, terpenes, steroids, prostaglandins and carotenes in the same class (Carey Giuliano, 2014). Other definition for lipid has also been suggested (Eoin, et al., 2005). They perform a variety of functions in living system including but not limited to structural integrity, energy storage, digestion and communication (Nelson Cox, 2005). Although lipids are essential for many body functions, not all lipids are required in same amount. Food and Agriculture Organization (FAO) recommends that total fat of the food contribute to 20-35% of energy for adults. This should include 8% saturated fatty acid(SFA), 11% poly unsaturated fatty acid (PUFA) and less than 1% trans fatty acid (TFA) (FAO, 2010). Chances of insulin resistance is more in overweight person in high SFA diet (Lovejoy, et al., 2002). Similarly, excessive TFA intake also increases the risk of cardiovascular disease (Song, et al., 2015). Fat content also affects taste. It is proposed that fat has a unique taste Oleogustus that is dependent of chain length and is unique from five conventional tastes: sweetness, sourness, bitterness, saltiness and umami (Running, Craig, Mattes, 2015). Butter produced from milk with high unsaturated fatty acid (UFA) was found to be more spreadable, softer and less adhesive (Bobe, Hammond, Freeman, Lindberg, Beitz, 2003). As the fat content and type effects health as well as taste and texture, it is essential to know the fat content of food. Fat sample is characterized by a variety of criteria and methods. The selection of the criteria and method depends upon the sample type, purpose, accuracy, precision, legal requirement as well as available funds. Hence, despite having limited significance for nutritional purpose, total lipid (TL) measurement is widely carried out as many food labelling regulations require the TL report. Similarly, iodine value can be used for unsaturation study when sophisticated chromatography or spectroscopy methods are unavailable (Greenfield Southgate, Review of methods of analysis, 2003). This review intends to compile the available methods of lipid analysis of food products. Focus will be given on the type of sample required, result provided, resolving capacity of each criteria and method. Only brief discussion will be done on the theoretical and experimental process of the method. Sample preparation is very essential part of analysis of lipid sample. A separate section is dedicated to sample preparation.          In order to analyze the lipid, suitable sample must be prepared. If the sample has lipid inside cells (such as meat) the lipid should be extracted from the cells (Christie Han, Lipid Analysis, 2012). Samples must undergo some pretreatment before they can be used as test sample. Depending on the nature of sample one or more of the following work is necessary. 2.1. Storage Vessel Plastic container should be strictly avoided to store lipids. Plasticizers can leach into the sample and contaminate it. Glass vessels or Teflon coated vessels should be used. The atmosphere should be argon or nitrogen to prevent oxidation. (Christie Han, Lipid Analysis, 2012) 2.2. Protection from Oxidation Unsaturated fatty acids are prone to oxidation from atmospheric oxygen. Once the oxidation starts, autocatalysis accelerates the process. Different products are formed during oxidation and it may follow various mechanisms. Light, heat, metals, enzyme are known to catalyze the reaction (Angelo, 1996) Oxidation interferes with lipid analysis not only by destroying the unsaturated fats but also by formation of conjugated double bonds which show strong absorption at UV, thus providing false positive results (Christie Han, Lipid Analysis, 2012) Elimination of oxygen is the major step in prevention of oxidation. Therefore, all steps should be done in nitrogen atmosphere as far as possible. Equipment should be flushed with nitrogen before experiments. Small amount of antioxidant like 2,6-di-tert-butyl-p-cresol, which do not interfere with analytical process, may be added. Excess of these antioxidant should not be used as they can facilitate oxidation in high concentration. (Christie Han, Lipid Analysis, 2012) 2.3. Drying of Sample Lipid sample containing water can make analysis difficult and might be a source of error. Solvents cannot penetrate sample with >8% moisture easily. Hygroscopic solvents like diethyl ether can absorb the moisture, decreasing its extraction efficiency. Low moisture also facilitates grinding and increases the surface area of sample (Shahidi Wanasindara, 2008). Petroleum spirit, the most widely used solvent requires completely dried sample. (Greenfield Southgate, Review of methods of analysis, 2003) Depending on the type of water present (free, adsorbed or water of hydration) different methods may be required for water removal (Bradley, Jr, 2010). Care should be taken during drying as high temperature might lead to decomposition and combination of lipids with other components. These associated lipids cannot be extracted by solvents. Lyophilization (freeze-drying) and vacuum drying methods are preferred drying methods. (Shahidi Wanasindara, 2008) 2.4. Particle size reduction (Grinding) Solid food sample might need grinding. Grinding increases the surface area and decreases the length through which solvent need to penetrate the sample (Min Ellefson, 2010). Care should be taken that the particles are not too fine, too much heat is generated or too much moisture is lost. (IUPAC, 1979) 2.5. Hydrolysis Lipids in food may be bound ionically or covalently with non-lipid components such as carbohydrate or protein. Solvents are not able to extract them efficiently. Therefore, lipid needs to be hydrolyzed with acid or alkali to turn them into free state. Significant error in lipid extraction is reported when no hydrolysis is carried out. (Min Ellefson, 2010) Hydrolysis also breaks emulsified fat. (Shahidi Wanasindara, 2008) Acid hydrolysis is used for most foods except diary and high sugar content food which require alkaline hydrolysis. Hydrolysis is not preferred when the lipid extract needs to be further analyzed for fatty acid components because they can cause decomposition and oxidation of the sample components. (Greenfield Southgate, Review of methods of analysis, 2003) The given sample of food might not be entirely lipid. The amount of lipid in the food sample is called total lipid concentration. It is usually expressed as percentage or per 100gm food (Moreau, 2005). Although total lipid is widely used for food labelling and regulation of food composition, it has limited value as it does not provide the type of molecule in the lipid. (Greenfield Southgate, Review of methods of analysis, 2003) There are various methods to determine total lipid in food like solvent extraction, non-solvent extraction, instrumental methods. The selection of methods depends on a number of factor which is discussed below. 3.1. Solvent Extraction In solvent extraction, the lipid component of the food is extracted by dissolving in suitable organic solvent(s). The solvent selectively dissolves the lipid while leaving the non-lipid portion undissolved. The solvent is then evaporated to leave fat residue. Total lipid is then determined gravimetrically as: -(i) The above data gives the total fat. However, a significant portion of the fat includes glycerol (from triglycerides) phospholipids and other unsaponifiable matters. Thus, corrections are required so as to represent the correct amount of fatty acids in the sample. The correction factor is provided by FAO. (Greenfield Southgate, Appendix 5, 2003) The extracted portion of solvent extraction is highly dependent on solvent use. Hence selection of solvent is discussed in detail next. Solvent Selection Ideal solvent should extract all lipids and lipids only. However, due to wide range of polarity of different lipid types, no single solvent can provide an ideal solution. Moreover, the solvent selected should preferably be low boiling, non-flammable, non-toxic in liquid as well as solid, easily disposable after extraction, inexpensive and non- hygroscopic. It should also penetrate sample thoroughly (Min Ellefson, 2010). Petroleum ether is the most commonly used solvent for its selectivity towards lipid, cost and availability. However, diethyl ether is better solvent for lipids but its fire hazard and hygroscopic nature makes it less favorable than petroleum ether. Ethyl ether and petroleum ether is also sometimes used alternately or together for extraction. (Pomeranz Meloan, 1994) n-hexane is preferred for oil extraction. (IUPAC, 1979) Mixture of polar and non-polar solvents has shown to extract all the lipids from most food. However, care should be given so as to prevent extraction of unwanted portion. The lipids extracted by this method without hydrolysis is suitable for further treatment to determine fatty acid fractions. (Greenfield Southgate, Review of methods of analysis, 2003) Alcohol-ether can be used to remove fat from tissue. Water-butanol is used in cereals. Chloroform-methanol is preferred for animal tissue (Pomeranz Meloan, 1994). Solvent extraction is the standard method of analysis for many types of food. Hence, it is widely used and is undergoing continuous improvement. There are different types of solvent extraction, each with its pros and cons. 3.1.1. Batch Extraction Batch extraction is a very simple, yet widely used method of extraction. The sample is mixed with one or more solvent which along with endogenous water (if any) forms multiple layer of varying concentration. As the lipids are more soluble in non-polar solvents than in water, lipid portion goes to the layer with more solvents and non-lipid component remains in the layer with more water. The lipid part is then separated using a separating funnel. The separation is based on partition principle hence multiple extraction of the aqueous phase is necessary to obtain most of the lipid. The weight of lipid not extracted is given by the equation below: (Pomeranz Meloan, 1994) -(ii) Where, is the weight of lipid remaining, the volume of aqueous layer, volume of solvent in each extraction step, the distribution ratio of lipid in solvent, the number of extraction steps. The selection of solvent is then done using the distribution ratio of lipids in known solvents. Folch method uses chloroform-methanol extraction followed by washing with water. This extracts all lipid from tissue except strandin which remains with the non-lipid phase. (Folch, 1957) Folch method was improved by Bligh and Dyer to improve the speed of extraction and purify the sample at the same time. (Bligh Dyer, 1959) Extraction using low toxicity solvents like hexane: propanol has also been developed. (Hara Radin, 1978) Batch extraction is usually slow and requires a large amount of solvent. When other faster and easier methods are available, this method is not preferred. However, as no sophisticated equipment is necessary, batch extraction is very useful where the cost of equipment outweighs the usefulness of more accurate data. 3.1.2. Continuous Extraction Continuous solvent extraction recycles the solvent used so that small amount of solvent can accomplish the equivalent extraction of several steps. This process is preferred for solid samples and sample where the distribution ratio is low. These samples need multi step extraction as very little lipid is extracted to the solvent in each step. (Pomeranz Meloan, 1994) Soxhlet extractor is widely used extractor for lipid. Although first developed to measure milk fat it has developed as a standard extractor for lipid as well as other substances. (Soxhlet, 1879) It has gone various improvements since its first publication and now various modifications are commercially available. Goldfish extraction is a faster extraction system which suspends the sample in the solvent vapour. Although faster than Soxhlet based system, it might not completely extract the lipid due to channeling i.e. solvent may take a preferential path in the solid sample and may not cover whole of the sample. (Moreau, 2005) As continuous extraction is faster and uses less solvents than batch extraction it is the most widely used extraction system. Moreover, the equipment used is not very expensive and can be used for extraction of other materials. However, these processes are slow and disposal of solvent is an everyday problem. 3.1.3. Pressurized Fluid Extraction Pressurized fluid extraction (PLE) is carried out in high pressure and high temperature. In literature, this process is also called Pressurized Solvent Extraction or Accelerated Solvent Extraction. The term ASE ®is the registered trademark of Dionex Corporation which manufactures pressurized fluid extraction apparatus commercially. (Dean, 2009) Richter et al. studied the effect of variables like temperature, pressure, solvent volume on extraction. Their work showed that the ASE ® extractor could provide results comparable to Soxhlet but with reduced extraction time and solvent volume. This is attributed to decreased viscosity of solvent, weaker bond between components and increased diffusion capacity of solvent at higher temperature. Increased pressure is primarily applied to keep the solvent liquid, however, it provides the added advantage of forcing the solvent into pores blocked by insoluble matter. (Richter, et al., 1996) However, there is evidence that PLE is not selective to lipids for certain foods. (Boselli, Velazco, Caboni, Lercker, 2001) Moreover, no significant difference was seen on lipid extracted from poultry meat between Folch, Soxlet or ASE ® method. (Toschi, Bendini, Ricci, Lercker, 2003) Pressurized solvent extraction can be highly useful in labs where routine extraction is required as it greatly reduces the extraction time and solvent use. On the other hand, the investment on the apparatus may not be economical if extraction is not carried out regularly. In all cases the stability of temperature sensitive components should be known before using PLE. 3.1.4. Supercritical Fluid Extraction Substance in temperature above its critical temperature and pressure is called supercritical fluid. (IUPAC, 1997) Solvent property of supercritical fluid was first demonstrated in 1879. (Hannay Hogarth, 1879) They have huge prospects in extraction because they combine the solubility power of liquid with penetration power of gas. Moreover, their solubility can be fine-tuned by changing the pressure and temperature. Carbon dioxide and water are the most promising fluid for supercritical extraction due to their non-toxicity and environmentally friendly nature. (Hedrick, Mulcahey, Taylor, 1992) 3.2. Non-Solvent Liquid Extraction In this method, the sample is treated with some liquid reagent which separates the lipid from sample and the lipid fraction is then measured. This method is mostly used to determine milk fat. They require specialized vessels for each method and cannot determine phospholipids. (McClements, 2003) Several methods are present: 3.2.1. Babcock Method 3.2.2. Gerber Method 3.2.3. Detergent Method 3.3. Instrumental Methods Different instrumental methods have been developed to determine the total lipid content of the sample. They rely on some physical properties that vary systematically with lipid concentration. (McClements, 2003) Based on the property measured it is mainly of three types: 3.3.1. Measuring Bulk Properties Density: Density decreases as lipid content increases. This relation can be used to know the percentage of fat in a sample. (McClements, 2003) Electrical Conductivity: Conductivity decreases as lipid content increases. Thus, it can be used as fat concentration measure. (McClements, 2003) Ultrasonic Velocity: This is a fast and non-invasive method for fat content calculation. Amplitude and brightness analysis can be used to find the fat content and also distribution. (Abdul, N, Mohd, Abu, Z, 2013) Moreover, attenuation(absorption) of ultrasound is linearly proportional to the amount of fat in the body. (Dukhin, Goetz, Travers, 2013) 3.3.2. Measuring Absorption of Radiation UV-VIS: Fatty Acid absorb UV light proportional to its concentration. This method requires sample preparation to remove substances like proteins and hydrophobic peptides which interfere with the measurement. (Forcato, Carmine, Echeverria, Pecora, Kivatinitz, 2005) Because of the extraction and dilution needed the process can be time consuming and labor intensive. (McClements, 2003) IR: Near infrared (NIR) spectroscopy is mainly used to analyze fatty acid content in food. (Mossoba, Azizian, Kramer, 2012) Fat show strong absorbance at 5.74 mm which provides rapid and online fat composition measure. (McClements, 2003) The carbonyl absorption is the major reason for lipids NIR activity. This method requires intensive calibration with other approved methods hence is mainly used for routine analyses of large number of similar sample. (Greenfield Southgate, Review of methods of analysis, 2003) NMR: NMR is also a non-destructive and fast method of total fat analysis. Although it requires a calibration curve, it is better suited than IR or UV because it can be operated by non-experts and the calibration curve is long lasting. (Oxford Instuments Molecular Biotools, 2010) X-Ray: Fat absorbs less X-Ray than lean meat. Hence, by building a proper calibration curve, fat content in meat can be determined by X-Ray absorption (McClements, 2003) 3.3.3. Measuring Scattering of Radiation Light and Ultrasonic Scattering: Light as well as ultrasound waves are scattered by oil droplets present in emulsions. The linear relation between concentration of droplet and light scattering can be used to measure total fat, provided no other interfering molecules exist. (McClements, 2003) X-Ray: Fat molecules show a sharp X-Ray scattering peak at 1.1 nm-1 while a water rich tissue shows a peak at 1.6nm-1. Thus, varying amount of fat can give a scattering profile which can be used for fat content determination. (Elshemey, 2011) 3.4. Other Methods 3.4.1. Solid Phase Extraction 3.4.2. Microwave Assisted Extraction Total Lipid Concentration is a very simple data about food. As lipid contain diverse chemical species, in addition to total lipid, the type of lipid and their distribution also plays a major role to determine the purity, nutritional value, aesthetic look and taste. Hence, complete information about the type of lipids is necessary for scientist as well as legal bodies. (McClements, 2003) Sample preparation is the most important part in most method to analyses lipids. As the lipid is extracted, care should be given to prevent the change of one form of lipid to another. Hydrolysis should be rigorously prevented as it reduces triglycerides and increases free fatty acids. Extraction should cause as less oxidation as possible. (Greenfield Southgate, Review of methods of analysis, 2003) Extraction in chloroform, chloroform-methanol and hexane-isopropanol is preferred. Storage of sample in cold at -20oC is preferred. (AAFCO Lab Methods Services Committee, 2014) The various method present have their advantages and drawbacks and the preferable method depends on the type of food and the type of lipid to me examined, (Greenfield Southgate, Review of methods of analysis, 2003) 4.1. Chromatography It is a very powerful tool for lipid analysis. It can give compete profile of the lipid molecules in the given sample. Chromatography separates the different components of lipid in fractions, these are then subject to spectrometric analysis which gives the molecular identity as well as relative concentration. IR, NMR and Mass Spectrometry are most commonly used. (McClements, 2003) These methods, although very reliable and comprehensive are very expensive due to the instrumental and reagent cost and is only carried out where complete molecular identification is required. (Greenfield Southgate, Review of methods of analysis, 2003) Three types are used: TLC: Thin Layer Chromatography is used to find concentration of different lipid groups. The TLC plate is prepared with suitable adsorbent and kept in proper solvent. A drop of sample is placed on one end and let to flow. The plate after separation to different fractions is compared to standard plates to identify the lipids. The spots can be analyzed further by GC, MS, NMR. (McClements, 2003) After the advent of HPLC, TLC use has decreased considerably. However, after the availability of pre-coated plates, the use of TLC for instant result is still carried out when there are few samples only. It is cheaper than HPLC. However, care during experimentation is required. (Christie, Thin-Layer Chromatography of Lipids, 2011) This method cannot be used to separate different types of phospholipids. (Zaima, Goto-Inoue, Adachi, Mitsutoshi, 2011) HPLC: High Performance Liquid Chromatography is now a preferred method for lipid analysis. This is because it is more versatile than TLC and operates at room temperature, thus can be used to analyses labile groups that cannot be done using GC. (Christie, Thin-Layer Chromatography of Lipids, 2011) GC: Gas Chromatography is the preferred method for analysis of trans fatty acid. It can also be used for triglycerides and fatty acids; however, methylation is necessary. (Greenfield Southgate, Review of methods of analysis, 2003) Fatty acids are non-volatile, hence before carrying out GC, the lipids are saponified and methylated to give Fatty Acid Methyl Esters(FAME) which are volatile and can be used for GC. (McClements, 2003) -(2) It is now possible to convert a lipid sample of a fraction of a milligram in size to the methyl ester derivatives, separate these by gas chromatography, and have a quantitative result in under one hour. (Christie, Chapter 1 Introduction and Summary, 2011) 4.2. Chemical Methods These methods are very cheap and do not require expensive machinery. However, only crude and average results are obtained. Following test gives different information on fat: Iodine Value: It gives the average degree of unsaturation in the lipid. The lipid to be analyzed is titrated with ICl and the consumption of ICl gives the amount of unsaturation in lipid. Saponification Number: It gives the average molecular weight of triglycerols. The triglycerols are saponified with KOH and the amount of KOH used is determined. This is the saponification number. High saponification number corresponds to low molecular weight and vice versa. Acid Value: It gives the amount of free fatty acid. Here, the lipid is titrated with KOH until the solution turns alkaline. Other acids may interfere with results. (McClements, 2003) 4.3. Instrumental Techniques Various instrumental techniques for fat analysis are present. Methods like NMR, IR, MS are usually coupled with chromatography. Measurement of density and refractive index can be used to measure change in chain length and unsaturation. (McClements, 2003) Lipids with high unsaturation undergoes aerial oxidation. This includes variety of reactions usually summarized as follows: reactants à ¯Ã‚ ¿Ã‚ ½ primary products à ¯Ã‚ ¿Ã‚ ½ secondary products (unsaturated lipids and O2) à ¯Ã‚ ¿Ã‚ ½ (peroxides and conjugated dienes) à ¯Ã‚ ¿Ã‚ ½ (ketones, aldehydes, alcohols, hydrocarbons) 5.1. Chromatography Loss of reactants as well as formation of specific products can be monitored by using time profile. 5.2. Oxygen Uptake Measures the amount of oxygen consumed over time while maintaining constant oxygen concentration on the reaction vessel. 5.3. Peroxide Value Measures the amount of peroxide formed by titration with iodine. 5.4. Conjugated Dienes Measures the concentration of conjugated dienes by UV spectroscopy (at 233nm for diene and 268nm for trines) 5.5. Thiobarbituric Acid(TBA) Measures the secondary products (aldehydes) in the sample. The sample is treated with TBA and absorbance measured at 540nm. The absorbance value corresponds with the concentration of aldehyde. 5.6. Accelerated Oxidation Tests The sample is oxidized in oxidation friendly environment and the time taken for rancidity to form is measured. These tests help to know the physicochemical characteristics corresponding to flavor, appearance, flow etc. 6.1. Solid Fat Content(SFC) Measures the fraction of fat present as solid. Density measure is mostly used (3) Where is the density at given temperature and are the density if it was completely liquid or solid at the same temperature. NMR signal decay rate is also being used recently. More solid component, faster is the signal decay. Differential Scanning Calorimetry uses latent heat measure are also used to measure SFC-temperature profile. 6.2. Melting Point Used when SFC is not required but only the temperature of melting is required. Due to different components present no sharp melting point is seen. Instead different melting points are used: Clear Point: The temperature at which fat completely melts and becomes clear Slip point: The temperature at which the fat in a capillary tube starts to slip. Wiley melting point: the temperature at which a disc suspended in alcohol-water mixture turns to a sphere. 6.3. Cloud Point The temperature at which a completely melted lipid starts to develop turbidity. 6.4. Smoke Point The temperature at which the lipid starts to smoke at standard condition 6.5. Flash Point The temperature at which a flash appears on the surface at ignition at standard condition 6.6. Fire Point The temperature at which a continuous flame stats to form at standard condition 6.7. Rheology The measure of deformation and flow. Viscosity, elastic modulus and other relevant flow or plasticity measure is used. (n.d.). (FOSS) Retrieved from Analytical Solutions for Food Analysis and Quality Control FOSS: http://www.foss.dk/~/media/images/ca/soxtec8000/soxtech_extraction_sketch-jpg AAFCO Lab Methods Services Committee. (2014, January). Crude Fat Methods Considerations. Retrieved from Association of American Feed Control Officials: http://www.aafco.org/Portals/0/SiteContent/Laboratory/Fat_Best_Practices_Working_Group/Crude_Fat_Methods_Considerations.pdf Abdul, H. M., N, B., Mohd, S. M., Abu, K. R., Z, M. (2013). The Use of Ultrasound As a Fat Measurement Sensor. International Conference on Smart Instrumentation, Measurement and Applications (ICSIMA), (pp. 315-320). Kuala LAmpur. doi:10.1109/ICSIMA.2013.6717974 Angelo, A. J. (1996). Lipid Oxidation in Foods. Critical Reviews in Food Science and Nutrition, 36(3), 175-224. doi:10.1080/10408399609527723 Bligh, E. G., Dyer, W. J. (1959). A Rapid Method of Total Lipid Extraction and Purification. Canadian Journal of Biochemistry and Physiology, 911-917. Bobe, G., Hammond, E. G., Freeman, A. E., Lindberg, G. L., Beitz, D. C. (2003, October). Texture of Butter from Cows with Different Milk Fatty Acid Composition. Journal of Dairy Science, 86(10). doi:10.3168/jds.S0022-0302(03)73913-7

Hephaistos: The Obscure Greek God :: Greek Mythology

Hephaistos: The Obscure Greek God Greeks are known for many things. We know them for their poetry, for their philosophy, their politics--and also we have come to know them for their childish, petty, lustful, little gods. These gods, vengeful in the extreme, have been a source of much literature. However, not all the gods have the same publicity agent, and have suffered in obscurity for much too long. One of these gods, one of the Twelve Olympians, has been obscure in the least. He is different in most ways from the other gods, and I am here to illuminate him further to you. His name? Hephaistos. This god will surprise you. He actually seems to have a crude sense of humor. He doesn’t seem to be vindictive, or very interested in the lives of mortals. He was simple, and he was ugly. It was as basic as that. Well, he has some interesting heritage, lets find out. Firstly, there is an interesting set of facts about the first moments of life for Hephaistos. One day, Zeus made Hera a bit jealous (as brothers and sisters in Kentucky can be) when Zeus was sleeping around with this and that female as various wild animals. Well, Hera was enraged so much, that she spontaneously conceived a child. I would LOVE to see something like that. She conceived and when Zeus noticed that Hera was pregnant, he was very angry himself. Moments later, she gave birth to Hephaistos. However, he was so very ugly and had a bad leg, that Hera tossed him to earth and disavowed his birth. It must be noted that there does seem to be a discrepancy. Some texts imply that Zeus tossed him to earth instead of Hera. He landed on the island of Lemnos (Seltman 99). That is why the people of Lemnos were his favorites and that was why he always headed there to relax and recuperate. Well, after being tossed into the ocean, Thetis picked him up and took care of him. Thetis is the same goddess who was mother of Achilles. Anyway, she took care of him, and he started making nice jewelry for her to wear. One day, she headed to court with the other gods, and all the women noticed the pretty baubles that were adorning Thetis. After they found out that it was long-lost Hephaistos, Hera went and asked him to come to Olympus.

The Constitutions of The World

In Constitutional Identity, G. J. Jacobsohn classifies the constitutions of the world into two categories. The first category is of transformative constitutions and the second category is of preservative constitutions. While a transformative or ‘militant' constitution seeks to change the prevailing social structure, a preservative or ‘acquiescent' constitution seeks to maintain the status quo. Using Jacobsohn's classification, the Constitution of India would clearly be placed under the transformative category. This is due to the fact that the intention of the Parliament while drafting the Constitution was to bring about ‘social revolution' in the country. This claim is further substantiated by the deliberate omission of any allusion to the law on family. It was intended that matters related to family would be the domain of state to facilitate reform in the law. Thus, most changes in laws governing family, flow from the state in the form of amendments and statutes, which are enacted to transform the society into one with more progressive values. An eminent example is the Hindu Marriage Act, 1955, which converted Hindu Marriage from ‘sacrament' to a ‘contract'. Nonetheless, reform needs to take place with regard to the prevailing values in society and make allowance for the demands of several cultures in a diverse country like India. In pursuance of the same, Article 44 which was the demand to evolve a Uniform Civil Code, to govern the personal laws of every religion, was placed in the Constitution as a Directive Principle of State Policy. These Directive Principles are goals that the government should keep in mind while it formulates policy. Article 44 reads: â€Å"The state shall endeavour to secure for the citizens a uniform civil code throughout the territory of India†However, courts too have played an important role in governing society through family. Apart from upholding the law, they have also tackled grey areas, resolved conflicting situations through reconciliation of different statues on the same subject and filled the lacunae. Illegalization of unlimited polygamy for Hindus, thus was, an important example of the positive influence of courts. This was taken further when conversion for the purpose of committing bigamy was also illegalized in Sarla Mudgal v. Union of India (hereinafter, ‘Sarla Mudgal') and later upheld in Lily Thomas v. Union of India (hereinafter, ‘Lily Thomas').The Sarla Mudgal CaseThe petitioner in this case was married for some year with three children from the wedding when she found out that her husband had contracted a second marriage with another woman, after converting to Islam. Her husband converted for the sole purpose of contracting a second marriage and ensuring that the provisions of Section 494 of the Indian Penal Code were not attracted. He argued, however, that Islam allowed for limited polygamy – four wives – thus, he could marry a second time even though his first wife remained a Hindu. The court held that marriage under the personal laws of one religion (here Hinduism) could not be taken to court for dissolution under the law of another different religion (here Islam) even if one of the parties embraced another different religion. This is because such a rule would violate the rights of the first spouse. However, the second marriage would be void because this very reason – that the first marriage subsisted, even after conversion of the spouse.Facts of the Lily Thomas CaseThe Writ Petition was filed by Smt. Sushmita Ghosh who had married Shri G. C. Ghosh in 1984 in accordance with Hindu rites. G. C. Ghosh had converted to Islam in 1992 and informed his wife of the change in religion. He stated that he wanted to marry Miss Vanita Gupta and so she should agree to a divorce by mutual consent. Change in religion is an accepted ground for divorce under section 13 of the Hindu Marriage Act, 1955. Smt. Sushmita Ghosh did not want a divorce and got in touch with her aunt and her father to intervene on her behalf. She, her father and her relative tried to persuade her husband to not go for a divorce. However, his decision remained unchanged. He stated that his wife could either divorce by mutual consent, or she would have to put up with his second wife, Ms. Vanita Gupta. Smt. Sushmita Ghosh was thus left with no alternative but to approach the courts.PETITIONER'S ARGUMENTSConversion Not Due To FaithThe first point raised by the petitioner, Smt. Sushmita Ghosh is that her husband, Shri G. C. Ghosh, had not converted to Islam a matter of faith, but had done so solely for the purpose of taking in a second wife. While unlimited polygamy was allowed for Hindus, prior to the enactment of the Hindu Marriage Act, it was abolished post 1955. However, limited polygamy is still allowed for the male followers of Islam in India and they can have up to four wives. Thus, it had become commonplace for many male members of the Hindu faith to convert to Islam for the purpose of marrying a second woman, divorcing their first wife and then re-converting back to Hinduism. The re-conversion was to ensure that property interests were not harmed. The petitioner proved this by referring to, firstly, a birth certificate of a son born to G. C. Ghosh from his second wife, wherein, his name appears as â€Å"G. C. Ghosh† and his religion is stated to be â€Å"Hindu†. Moreover, the mother's (his second wife) name appears as â€Å"Vanita Ghosh† and she too is a â€Å"Hindu†, according to the birth certificate. Secondly, the electoral roll of the constituency indicates the same, as does the respondent's visa to Bangladesh. In fact, he signed the marriage certificate issued by Mufti Mohd. Tayyeb Qasmi, is signed by him as â€Å"G. C. Ghosh†.Removal of Burden of ProofThe second contention raised was that since the judgment in Sarla Mudgal validated their case, conviction should take place without any need for proof. However, it was held that the conviction could not be made certain based on only a statement of admission made outside the court. This was because the provisions of the Indian Penal Code demanded that proof of not only the first marriage, but also the second marriage. This is still a legal obligation and admission of the marriage by the person being accused of bigamy, is not enough to constitute the requirement. The matrimonial ceremonies needed to be shown.RESPONDENT'S ARGUMENTSDifference with regard to Sarla Mudgal – Article 20(1)It was contended that the law propounded in Sarla Mudgal, would not be applicable to the present case as that case was not related to people whose marriages were solemnized before the judgment pronouncing them void was passed. Even though these marriages would be violative of the law, there could be no retrospective application. The court however, rejected this argument. It said that no new law had been introduced, but the old, existing provisions of the governing statute had been interpreted. It is a rule of law that the interpretation of a provision goes back to the date of that provision and is not, in its nature, prospective. Thus, the second marriage would be declared void and article 21 of the Constitution which states that â€Å"no person shall be convicted of any offence except for violation of a law in force at the time of the commission of the Act charged as an offence, nor be subjected to a penalty greater than that which might have been inflicted under the law in force at the time of the commission of the offence†, would not be affected. Violation of Article 21 and 25The other contention raised by the counsel was that the Sarla Mudgal judgement would be violative of Articles 21 and 25 of the Indian Constitution. In the case of Article 21 which states that â€Å"no person will be deprived of life or liberty except according to the procedure established by law†, the court said that this contention was misconceived. Thus, it would be premature to say that the judgement will result in deprivation of the life or liberty of either of the parties because the Sarla Mudgal judgement neither created a new law, nor changed the procedure for the prosecution.Another contention raised by the respondent was that the judgement would violate Article 25 of the Constitution, which guaranteed the right to freedom of conscience and the right to profess and propagate a religion. However, such an argument does not hold when the Hindu Marriage Act, 1955, explicitly abolished polygamy in the Hindu religion and further, section 17 of the Act made void any marriages if any party had a living spouse, even after the marriage had been solemnised. Freedom guaranteed by the Constitution was to be exercised by individuals, until they encroached upon another's freedom. Moreover, if the act fitted under section 17 of the Hindu Marriage Act, its penalty was prescribed in section 494 and section 495 of the Indian Penal Code, 1860. The court commented on the contention raised in Sarla Mudgal that â€Å"making a Hindu Convert liable for prosecution would be against Islam†. The court found this argument to be ‘ignorant' of the nature of the religion of Islam.COURT'S DECISIONApplying Natural Justice Further, the court posed that conversion for the purpose of bigamy could not be squared with the principles of natural justice and equity. Natural justice constitutes in procedures or principles that are thought to be wrong, inherently. Here, the court agreed with the view of Justice M. C. Chagla in Robasa Khanum v. Khodadad Irani. The judges were of the opinion that if a man converted to Islam, to take in a second wife, during the subsistence of his first marriage, the effect on both wives would be undesirable. Since the law does not recognize the second marriage as valid, the status of the second wife would be that of a concubine and children born out of that marriage would be considered illegitimate. Though the first marriage will still persist legally, there would be practical problems with it. Necessity of the Uniform Civil Code The need for a Uniform Civil Code was not the primary question addressed by the judges in Lily Thomas, but it was referenced by both the judges in their separate judgments. Various cases discussing the notion of a uniform personal law were also mentioned. After a perusal of some judgments, it was commented by Justice Sahai in a separate judgment, that the Uniform Civil Code was highly desirable. However, the ‘social climate' of the society needed to be taken into account. Thus, a comprehensive Uniform Civil Code that takes into account all stakeholders and caters to everyone's interests could only be brought into existence if leaders took the responsibility of bringing about reform by changing the minds of people in their communities. Thus, the matter was assigned to the 18th Law Commission which would examine the feasibility of the Uniform Civil Code, in consonance with the Minorities Commission. The court clarified its stance on Article 44 of the Constitution, affirming that the courts had no jurisdiction whatsoever in giving direction for the implementation of a common Civil Code for personal laws. The Directive Principles of State Policy are not to be enforced by the courts because they do not create rights in favour of any person or persons. They are simply guidelines by the Constitution to the State, which is why they were included in the non-justifiable section by the Sapru Report of 1945. Arguments of the person

Los 10 mejores estados para vivir en EE.UU. en 2019