Paper Details
COMPARATIVE ANALYSIS OF GLOBAL DISABILITY RIGHTS FRAMEWORKS
Authors
Shivanshu Katare, Kusum Kumari, Vikas Yadav
Abstract
The comparative analysis of global disability rights frameworks reveals the varying degrees of legal, institutional, and policy-based protections afforded to persons with disabilities across jurisdictions. Despite the adoption of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), national implementations differ in scope, enforcement, and inclusivity. This study critically evaluates the disability rights laws of selected countries, including the United States, India, Sweden, South Africa, and Australia, focusing on core areas such as accessibility, education, employment, healthcare, and political participation. Through doctrinal and policy analysis, the paper examines how legal standards, cultural contexts, and state capacities shape the realization of disability rights. The research highlights that while developed nations often exhibit advanced infrastructural and legislative mechanisms, they may still fall short in practice due to bureaucratic inertia or systemic bias. Conversely, some developing nations show progressive constitutional commitments but lack implementation due to limited resources and institutional fragmentation. The role of judicial activism, civil society engagement, and international monitoring mechanisms is explored in driving compliance and advancing disability justice. By juxtaposing legal texts and rights-based outcomes, the study identifies best practices and critical gaps within each system. The analysis underscores the need for harmonizing national laws with international norms and fostering intersectional approaches that recognize the compounding effects of disability with other forms of marginalization. The paper concludes by advocating for strengthened global cooperation, capacity-building, and context-sensitive legal reforms to ensure substantive equality and dignity for persons with disabilities.
Keywords
Disability rights, UNCRPD, comparative law, accessibility, legal frameworks, human rights
Citation
COMPARATIVE ANALYSIS OF GLOBAL DISABILITY RIGHTS FRAMEWORKS. Shivanshu Katare, Kusum Kumari, Vikas Yadav. 2025. IJIRCT, Volume 11, Issue 3. Pages 1-9. https://www.ijirct.org/viewPaper.php?paperId=2505022