Reasonable Accommodation and Disability: a Comparative Analysis

Abstract

After a brief overview of the content of the United Nations Convention on the Rights of Persons with Disabilities, the present paper provides a comparative analysis of European Union law, the Italian, Spanish, Indian and US legal systems on the subject of reasonable accommodation. The article focuses mainly on the definition of a person with disabilities, the concepts of “reasonable” and “proportionate” accommodation, and the remedies to be applied in case of infringement of the employer’s obligations.