COMPARISON OF LABOUR LAWS IN DIFFERENT COUNTRIES

Abstract

A systematic review of literature was done to compare the labour laws of different countries. Two major theories were noticed. One theory contends that strict labour protection laws and their enforcement will hamper economic growth of the country, with or without impact on employment. So, they argue for complete deregulation and even a universal labour laws across countries to enable transnational corporates operate in different countries. In USA and UK, privatisation and entrusting regulation to themselves are followed. The level of protection of labour laws in these countries is low. Their economic growth has now been matched or overtaken by China and Brazil with stricter laws for protection of labour rights. This trend was evident by comparing these four countries based on both ILO framework and CBR framework. Thus, the argument that economic growth will be impeded in countries with high level of rights protection is contested. The alternative theory that such protection does not negatively impact economic growth is supported by the findings of this analysis.