The Servant's Right to Strike in Public Sector; Prohibition: or Restriction, Comparative Study of France, United Kingdom and Iran

The “Right to Strike”، as a fundamental right for demanding the legal claims of employees has maintained an important role in regulating the labour relations in the last decades. Importance of this fact، especially about the public sector servants with attention to organic sensitivity and function of this section، becomes multiple. Recognition of this legal phenomenon requires understanding the public sector servants، and illustrating the general approaches about recognition and regulation of this right. French approach is based on recognition and ensuring of this right about the mentioned servants with some restrictions and prohibitionsi، while English approach is based on denying the right natured of this right. With attention to legal vacuum of public sector servants’ right to strike in Iran، in this paper، we are going to investigate and analyze each of the mentioned approaches and theirs affects on regulating of the servants’ right to strike، and then select a dominant approach.