Comparative Sociological Study on the Concept of "Reasonable Accommodation" in Anti-Discrimination

本研究旨在探讨“合理便利”这一概念在国内和国际法律的体系中的引入，如英国的《残疾人歧视法》和联合国《残疾人权利公约》。第二，合理便利的概念源于1990年《美国残疾人法》，并逐渐在各国残疾人法中得到推广。最后，通过对西班牙、法国、意大利、韩国等国残疾人反歧视立法的收集和分析，结合国际趋势，阐明了残疾人反歧视立法的未来发展方向。为了重新组织残疾人法和引入关于残疾人的反歧视立法，强调了这些问题。

This research aims to examine the concept of "reasonable accommodation", which has been introducing in the national and international legal system such as the Disability Discrimination Act in the UK and the UN Convention on the Rights of People with Disabilities.Firstly, focusing on the UN Convention on the Rights of people with disabilities, this study gave an overview of the concept the drafting and elaborating process of the Convention. It also clarified the significances and effectiveness on the concept in the articles, Article 5(Equality and non-discrimination), Article 24(Education) and Article 27(Work and employment).Secondly, the concept of reasonable accommodation derived from the Americans with Disability Act 1990, and gradually spread out the disability laws in the several countries. Therefore the concept reflects the achievements and limitations of the policies on disability in a certain country.Finally, Anti-discrimination legislation on disability has been introduced in Spain, France, Italy and Korea etc. Collecting and analyzing these Acts, this study clarified the futures of the act in the context of international trends.In the report of this study, issues have been emphasized in order to reorganize the disability laws and introduce anti-discrimination legislation on disability.