ABSTRACT
This chapter has a special focus on the comparative aspect of this book, examining both the extent to which employment protection rights exist at all in particular jurisdictions and in particular at the extent to which the clergy are treated as employees. Inevitably a selection has to be made and whilst there is discussion of the position in the US and in European countries where the predominant ecclesiology is Roman Catholic, there is also discussion of the position in Nordic countries. This is interesting as, historically, ministers of the Lutheran Church have been regarded as employees and so this chapter asks if this has led to any problems in dealing with disciplinary proceedings against the clergy, especially where there is a theological element involved.
