CEU Electronic Theses and Dissertations, 2013
| Author | Bitiukova, Natalija |
|---|---|
| Title | Workplace Accommodation of Religion and Belief: Comparative Analysis of U.S. and European Non-discrimination Standards |
| Summary | The main question this thesis aims at answering is whether European practice should follow the Unites States model in terms of establishing a separate duty for an employer to reasonably accommodate religion and belief in the workplace. Although a strong conceptual framework for adjudication of such religious claims exists, the European Court of Human Rights is reluctant to adhere to it, as the analysis of Article 9 cases shows. The thesis questions the assertion that ‘standard’ concepts of European non-discrimination law, namely direct and indirect discrimination and/or positive action, can serve as a depository for a duty of workplace accommodation. The analysis further shifts to Title VII jurisprudence of the United States courts exploring the strengths and the limitations of the American religious accommodation model. |
| Supervisor | Durham, W. Cole |
| Department | Legal Studies LLM |
| Full text | https://www.etd.ceu.edu/2013/bitiukova_natalija.pdf |
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