Summary

The provisions concerning the termination of the contract of employment in Estonian and French labour laws have several common features. However, there are also marked differences. The main difference between French and Estonian labour laws is the fact that apart from the labour laws, the precedents, collective agreements and common law play an important role in France. The Estonian Law on the Contract of Employment enables the employer to terminate the contract of employment on 11 grounds, while the French Code du travail provides 2 grounds, economic and personal motives, for the termination of the contract of employment. The author analyses in depth the two country's practice in terminating the contract of employment both for determined and undetermined working hours, and the role of employees' representatives in terminating the contract of employment. Also, the author looks at the implications of economic and personal motives in French labour law.