Funktionshindrad - med rätt till arbete?: en komparativ studie av arbetsrättsliga regleringar kring arbete och funktionshinder i Sverige, England och Tyskland

This doctoral thesis examines labour market legislation concerning disability and work in Sweden, England and Germany. In order to provide increased access to the labour market for people with disabilities, all these countries have undertaken more of less far-reaching legislative measures over a number of decades, both in line with, or as a result of, general labour and employment legislation, but also as more specific parts of labour market regulations. Obviously legislators in all three countries, and more recently also in the European Union, have realised that access to the labour market is a vital and important part of societal inclusion and participation for this large group of people. The study provides a legal dogmatic and comparative analysis of the field of law and raises questions about how rights are provided to individuals under these laws in the different national settings and in what way the legislation represents or reproduces different normative patterns. Three different legal areas appear all over the examined legal field, these are positive measures, employment protection and discrimination law. Legislation on positive measures, such as quota-legislation and regulations on supported or sheltered employment, vary widely between the countries, as do employment protection legislation, while the disability discrimination legislation in the different countries is turning into a more EC-conform shape in line with recent EC-legislation on discrimination