Comparative study of anti-discrimination and equality laws of the US, Canada, South Africa and India

The aim of this study is to compare and contrast anti-discrimination and equality laws in the US, Canada, South Africa and India, with a view to inform future development of EU anti-discrimination laws. Comparative law is of great value, particularly in the equality field, where there is increasing cross-pollination across different jurisdictions. At the same time, comparative law carries with it important challenges, as the harmonising project of the EU has itself demonstrated.

The four jurisdictions to be examined here share English as a common language as well as, in varying degrees, a common law heritage.1 However, there are significant differences in historical, socio-economic and political contexts as well as in legal institutions. The challenge is therefore to illuminate universalisable conceptions while at the same time recognising context specificity.

The European Network of Legal Experts in the Non-discrimination Field http://www.non-discrimination.net/

European Commission: DG Justice: Tackling discrimination http://ec.europa.eu/justice/discrimination/index_en.htm

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