Disability Acts in Various Parts of the World
Thursday, April 24th, 2008When President Bush introduced new legislation called as Americans with Disability Discrimination Act in nineties, he claimed that this act will act as comprehensive declaration of equality for the people with disabilities. Various countries all over the world including Russia, Japan and European Union members have expressed their desire to have similar act in place. The image of United States being leader in ensuring equal rights for people with disabilities, with other countries following the precedence set by United States, turned out to be only partly correct. The reality is however more complex. A host of social, economic, cultural and political factors exclusive to each country play their role in broadly different approaches to disability discrimination.
Nevertheless, precedent set up by ADA has influenced various countries to pass legislation preventing disability discrimination. The UK passed the Disability Discrimination Act(DDA) in 1995, Australia passed the act in 1992. Each of the legislation was influenced by US legislation ADA to certain extent. The language and content was borrowed from it.
Compared to DDA in the UK, Australian Disability Discrimination Act is quite compelling, specific and comprehensive. The UK law is much broader, less specific and more oriented towards providing guidance. Critics have claimed that this law is not suitable for prevention of discrimination against the disabled. However, the British Disability Discrimination Act has undergone amendments over a period of time to include additional areas and larger range of activities