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Howard's semi-circle theorem is generalized for three-dimensional disturbances in a non-Boussinesq stratified fluid with a mean flow varying horizontally and vertically. In case of Boussinesq approximation Howard's and Rayleigh's theorem are extended for three-dimensional disturbances in a fluid with a mean flow varying only with respect to the latitude.

On the Stability of Three-Dimensional Disturbances in Stratified Flow with Lateral and Vertical Shear