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                            Sandstrom's theorem suggested that buoyancy fluxes can not drive the overturning circulation, an idea that physical oceanographers continue to debate. This paper attempts to provide the most fundamental examination of Sandstrom's theorem that is possible. We conclude that the fundamental role of buoyant forcing in the modern ocean is to damp the circulation, that buoyance fluxes drive significant levels of turbulence, that buoyant turbulent generation is not solely proportional to molecular diffusivity and that some of the main pathways to turbulence are non-Boussineq. We conjecture that the ocean might not be constrained by the `Anti-Turbulence' theorem. 
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