欧盟成员国中小学教师开除与解雇制度研究

On the Dismissal System for Teachers in the Primary and Lower Secondary Schools in the Member States of European Union

在欧盟范围内，由于各成员国对中小学教师职业身份的定位不同，因此教师与用人单位因工作而建立的法律关系的性质也有所不同。开除与解雇是用人单位基于法定事由和程序而单方终止这种法律关系所使用的两种手段。分析、比较欧盟各国的不同模式及具体做法，对完善我国的教师管理和教师聘任制具有重要借鉴意义。

In the EU， the employment status of teachers in primary and lower secondary schools falls into different groups for different countries. Thus， the legal relations between the teacher and employer are different. According to the juristic reasons and procedures， dismissal is a measure to terminate the legal relation by the employer. However， the meanings of dismissal are different. The analysis and comparison on the models of termination and practice will have great implication for our own management and recruitment of teachers.