The current civil service disciplinary rules are diverse in two Middle East Gulf Countries: Saudi Arabia and Kuwait. This article examines the differences, similarities, and trends between these two legal systems, while exploring the major issues which are illustrative of the fundamental principles of both. The article then reviews the relative merits of each legal system, and it proposes suggestions for maintaining administrative reform and improving efficiency in the civil service.
Abd E. Massadeh, An Analysis of the Civil Service Disciplinary System of Saudi Arabia and Kuwait: An Islamic Perspective and A Comparative Overview, 10 Penn St. Int'l L. Rev. 461 (1992).