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Tort Liability and Employment Law: Intertwined Concepts

Tort liability and employment law have a long and intertwined history. The "control test," initially used by English courts to determine employee status, originated in tort law. Employers can be held liable for damages caused by their employees to third parties and property, provided an employment relationship exists and the employee acted under the employer's control or direction. The evolution of tort liability has often mirrored developments in employment law. A crucial element in establishing employer liability is whether the individual who caused the damage was indeed an employee. This determination rests on the definition of "employee" as established by employment law. Civil courts adjudicating tort claims must interpret the Employment and Labor Law to ascertain the existence of an employment contract between the employer and the injured party. The court cannot apply a different standard for employee identification than the one defined in the Employment ...
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Private International Law and Transnational Employment Relationships

Transnational employment relationships—where employer-employee connections span multiple countries—are increasingly common in today’s globalized world. These relationships arise in various contexts. For example, employees working for the Commercial Bank of Ethiopia in Djibouti are employed by the bank in Ethiopia, but they work abroad. Similarly, Ethiopians seeking better opportunities abroad may work in foreign countries, while foreign nationals may take up employment in Ethiopia. In these and other similar cases, employment disputes raise significant issues in private international law. These issues include: The jurisdiction of the court where the dispute will be heard Which country’s employment laws will govern the dispute Whether a judgment from a foreign court can be recognized and enforced Before addressing these points, a court must first determine whether the case presents a private international law issue. This is typically done by examining whether t...

Employment and Labor Law: Clarifying Terminology and Scope

The terms "Employment Law" and "Labor Law" are often used interchangeably, leading to confusion. While some jurisdictions differentiate them, others, like Ethiopia, use a single term – "Employer and Labor Law" – to encompass both. This distinction, where it exists, generally revolves around the nature of the employment relationship: Employment Law: Focuses on the individual relationship between an employee and an employer, arising from the employment contract. It governs matters like hiring, wages, working hours, termination, and individual rights. Labor Law: Deals with the collective relationship between employers, employees (often represented by unions), and the state. It covers areas like collective bargaining, trade union rights, strikes, and dispute resolution mechanisms. However, this distinction isn't universally applied. Many countries, including Ethiopia, consolidate both aspects under a single l...

The Legal Effect of Transfer of Undertaking through Foreclosure on Employees Right: Cassation Case No.: 33314

Legal Rule (Interpretation of Law): 1.     Transfer of Ownership vs. Assumption of Obligations: When a bank forecloses on a business and takes possession of it, this does not automatically mean the bank assumes all the obligations of the previous owner, especially concerning employment contracts. The key factor is why the bank took possession. If it's simply to sell the assets and recover the debt (as in this case), the bank is not obligated to continue the business or honor pre-existing employment contracts. 2.     Purpose of Foreclosure: The purpose of foreclosure under Proclamations 97/90 and 98/90 is for the bank to recover its loan by selling the collateral, not to take over and run the business indefinitely. The bank's actions must be consistent with this purpose. 3.     Employee Rights in Business Transfer: While Article 16 of Proclamation 377/96 (the Labor Proclamation) protects employee rights when a business changes owners...

Key Ethiopian Labor Law Cases: Work Certificates, Wages, and Employment Rights

Introduction Ethiopian labor law, primarily governed by Proclamation No. 377/1996 and its amendments ( Proclamation No. 1156/2011 ), provides a robust framework for addressing employment disputes. This blog post examines key cassation cases that clarify legal obligations regarding work experience certificates, wage disputes, termination procedures, and employee rights during business restructuring. These cases underscore the importance of statutory compliance and procedural fairness in Ethiopia’s labor law framework. Work Experience Certificates Case No. 215642 (Dec 27, 2015 E.C.): Pilot Work Experience Certificates Key Legal Rule : Per Case No. 111337 and Article 12(8) of Proclamation No. 1156/2011 , employers are not required to include flight hours in a pilot’s work experience certificate. This interpretation remains consistent with the law’s intent, and no legal basis exists to amend it. Context and Outcome : The cassation bench upheld the prior ruling that flight hours are not ...

Key Labor Law Cases in Ethiopia: Jurisdiction, Termination, Wages, and Bonuses

Introduction Ethiopian labor law, primarily governed by the Labor Proclamation No. 377/1996 (as amended by Proclamations No. 466/1997 and No. 1156/2011 ), establishes a structured framework for resolving employment disputes. This blog post examines pivotal cassation cases that clarify critical legal rules related to jurisdiction, termination, wage deductions, wage increases, and bonus eligibility. These cases highlight the importance of adhering to statutory procedures and respecting the administrative framework of employers under Ethiopian law. Case No. 192951: Jurisdiction in Individual Employment Disputes Key Legal Rule : Under Labor Proclamation No. 377/1996 (as amended), individual employment disputes are subject to a single level of appeal, with the regional high court’s decision being final unless a fundamental legal error is identified by a cassation bench. Applying regional laws, such as Oromia Proclamation No. 216/2011 , to extend appellate jurisdiction beyond this framewo...

Navigating Dismissal: Key Rules in Ethiopian Employment Law

Understanding the grounds for lawful employee dismissal is crucial for both employers and employees in Ethiopia. Ethiopian labor law, as interpreted through various court cases, establishes specific rules regarding termination, particularly concerning dismissal without notice and insufficient reasons. Let's break down some key principles illuminated by recent legal precedents. Dismissal as Retaliation is Illegal Case No. 105921 sets a clear precedent: an employer cannot terminate an employee for asserting a legitimate legal right. In this instance, dismissing an employee for claiming their rightful bonus under Article 26(2)(c) of Proclamation No. 377/96 was deemed unlawful. This underscores that dismissal must be based on valid, justifiable reasons related to the employee's conduct or the employer's operational needs, not as a punitive measure for exercising legal entitlements. Strict Rules on Absenteeism Justify Dismissal Without Notice Several cases highlight the stringe...