Lost in translation: language and cross-national comparison in industrial relations

Pietro Manzella

Comparative research is universally regarded as a fascinating but challenging task, among others because of the relevance of the national differences stemming from distinct historical, economic, legal and cultural developments. Affording a comparative perspective might serve to identify a certain degree of correspondence among practices and processes in place in different contexts and to assess their effectiveness, particularly considering their applicability elsewhere, away from the original legal framework. Yet when engaging in comparative analysis, consideration ought to be given to those institutional changes in societies that are peculiar to each legal system. In so doing, many problems arise in terms of equivalence, as a number of authors have pointed out. Kahn-Freund has posited that the variations in the organisation of power among different countries can prevent and even frustrate the transfer of legal institutions, thus affecting the effectiveness of comparison. This is because “even in very similar societies, the role played by law may be very different, owing to the tempo and the sequence of economic and political history”.

Lost in Translation PDF File


Discourse of termination of employment at fiat: a conceptual, legal and terminological analysis

Terminological and conceptual differences within the general discourse of labour and employment law comprise the object of studies covering different research fields, e.g. Comparative Labour Law, Industrial Relations, Legal Studies, Semiotics, Social Sciences, and Translation Studies. A significant amount of scholarly attention has been paid to conceptual differences arising from the notion of ‘termination’. In addition, a substantial body of rese­arch has been devoted to the investigation of those concepts in the disciplines of labour law and industrial relations which pose special challenges from a terminological point of view when compared and contrasted with apparently similar notions in other national legal sys­tems. Taking as a point of departure the previous literature, this paper provides a compara­tive analysis of some concepts associated with the termination of employment in a number of countries, primarily considering aspects of relevant national labour laws, then further investigating issues from both the linguistic and semantic point of view. The adopted appro­ach will be of an interdisciplinary nature, mainly involving notions pertaining to linguistics and industrial relations. In this connection, this paper will examine a practical case, namely the case of FIAT, a multinational with its headquarters in Italy. The system of labour law in a number of countries where FIAT has employees will be briefly analysed, followed by some considerations of a terminological and conceptual nature. The analysis will point out a number of questions in both linguistic and conceptual terms that are of interest in comparative terms, as the result of different cultural, historical and political developments. ­

Termination of Employment PDF file

Contrepois Presentation at IMISCOE Conference


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