Comparative Study in Disability Law of Thailand, United Kingdom and United States of America
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2011-02-07
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Journal of Ratchasuda College for Research and Development of Persons with Disabilities
Abstract
The purposes of this comparative research were to explore the features of disability laws/policies regarding disability in terms of their different and similar natures of Thailand, United Kingdom and the United States of America, and to address social, economic and political context influencing on ontology and normative notion of disability policies of those countries. Features of disability policies were mainly derived and collected from The Rehabilitation of Disabled Persons Act 1991 (B.E.2534) of Thailand, The Disability Discrimination Act 1995 (DDA) of UK and The Americans with Disability Act 1990 (ADA) of US and other documents regarding such disability policies which were available on internet as possible as finding out. Typology analysis and interpretation were administered on these particular data. The results revealed that the 4 similar features of disability policies of those countries were definition of disabilities, promotion of occupation/employment for PWDs, human right and dignity concern and governmental financial support. In contrast, the 4 different features of disability policies were attitudes towards PWDs, service orientations, law monitoring and punishment, intentionality of promotion of occupation/employment for PWDs and participation of PWDs as policy maker. Empowerment orientation, capitalism and human right movement shaped disability policies from philanthropic/charitable model to medical model and social model eventually. Although disability law/policy of UK and US was focused on empowerment and independent living as a social model, discrimination and stigma were still occurred and critical problem of PWDs. These events probably implied that quality of life of PWDs could not only be enhanced by law but also morality and consciousness of society or community.
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Journal of Ratchasuda College for Research and Development of Persons with Disabilities; Vol.1 No.2 July-December 2005; 37-58