A Comparative Analysis of the Discrimination Against Persons with Disabilities (Prohibition) Act 2018, and the United Kingdom Equality Act 2010: Prospects and Challenges

This paper provides a comparative analysis of disability rights laws in Nigeria and the UK, focusing on Nigeria's Discrimination Against Persons with Disabilities (Prohibition) Act, 2018, and the UK Equality Act 2010. Using a doctrinal research methodology, the study identifies key differences, finding that the UK Act offers a more robust framework with specific disability definitions, clear accommodation provisions, enforcement mechanisms, and positive action measures. In contrast, Nigeria's Act is broader but less detailed, lacking clear guidelines for enforcement and accommodation. The research recommends revising Nigeria’s legislation to adopt a more comprehensive disability definition and expand its scope to better align with international standards.