Vanderbilt Journal of Transnational Law

First Page



Age, alienage, ethnicity, race, religion, and sex lead to differential treatment of individuals the world over. Employment discrimination is felt most acutely in those industrialized nations where one's income level is the major determinant of so many other things: where one lives, what one wears, how one's children are educated. Concern over the social and economic consequences of employment discrimination has led to the development of new legal techniques on both sides of the Atlantic. The recent enactment in Britain of the Sex Discrimination Act, 1975, and the Race Relations Act, 1976, invites a comparison of those statutes and related developments with American law. This article seeks to provide the skeleton of such a comparison; fleshing out must await the rendering of decisions under the new British statutes as well as further interpretation of our own statutes. The perspective of this essay is American because of the greater volume of American case law, and the writer's American background. Hopefully, an examination of British efforts will enable us better to evaluate our own law.