1 1944, as amended in 1963.

2 Sec. 32 of the original Ordinance; amended in 1963, and now incorporated as sec. 62(b) of the Civil Wrongs Ordinance (New Version) 1968.

3 Per Cohn, J., Finstein v. Secondary School Teachers' Union (1971) 25 P.D. 129, at 131Google Scholar: the strike was referred to as “a sacred tradition which is beyond the realms of examination”. The 1963 Amendment to the Civil Wrongs Ordinance sec. 32 was based on the same conception.

4 Settlement of Labour Disputes (Amendment No. 2) Law, 1972, which introduced sec. 37A–D of the Law, 26 L.S.I. 77.

5 Settlement of Labour Disputes Law, 1957, 11 L.S.I. 47.

6 Electric Wire and Cable Co. Works Cttee—Electric Wire and Cable Co. (1972/73) 4 P.D.A. 122 (Hereinafter referred to as Electric Wire and Cable Co. Case); Hebrew University, Jerusalem—Union of Assistants, Instructors and Lecturers of the Hebrew University, Jerusalem (1973/74) 5 P.D.A. 115.

7 Electric Wire and Cable Co. Case (1972/73) 4 P.D.A. 122, at 134.

8 The actions were based upon the Civil Wrongs Ordinance (New Version), 1968, sec. 49.

9 Motion 415/78, 433/78, Pri Taim Inc. and Others v. National Union of Marine Officers and others, Haifa District Court 19/2/78, not yet published.

10 The claim was made in the context of the Settlement of Labour Disputes (Amendment No. 2) Law, 1972, sec. 9, which preempted imposition of prison sentences for breach of court orders “concerned with participation in a strike”.

11 Furthermore the inclusion in the terms of the injunction of an order to the strikers to unload the goods themselves cannot be explained by the non-integral activity of detention of goods but only by the damage caused by the very act of striking.

12 Motion 1736/77, Mifali Rechev Ashdod Inc. and Others v. Chizick and Others, Haifa District Court, 25/12/77, not yet published.

13 There were also other grounds, with which we do not take issue, for the ratio decidendi that the Labour Courts did not have exclusive jurisdiction over the case at hand.

14 There are other Civil Wrongs Ordinance torts which might also result from acts integral to exercise of the liberty to strike in some situations: according to some interpretations of the tort of negligence, many strikes would be exposed to actions in negligence; and some kinds of strikes might be, integrally, exposed to actions for trespass or private nuisance. While these latter torts will not be examined in depth here the possibility of strikers incurring liability for them will be taken into consideration.

15 Tedeschi, , Studies in Israel Private Law (1966, hereinafter referred to as Tedeschi) 139–180Google Scholar; Fleming, , The Law of Torts (4th ed., 1971, hereinafter referred to as Fleming) 599–601Google Scholar, 603.

16 See Wedderburn, , “Inducing Breach of Contract and Unlawful Interference with Trade” (1968) 31 Mod. L. R. 440.Google Scholar

17 Trades Union and Labour Relations Act, 1976, sec. 3(2). Participation in a strike may still result in exposure to tortious liability beyond the limits of the “industrial disputes” formula: see Simpson, , “‘Trade Dispute’ and ‘industrial Dispute’ in British Labour Law” (1977) 40 Mod. L. R. 16.CrossRefGoogle ScholarWedderburn, , “The New Structure of Labour Law in Britain” (1978) 13 Is.L.R. 435.Google Scholar

18 Civil Wrongs Ordinance, 1944, sec. 32.

19 Leo Beck School v. Secondary School Teachers' Union (1962) 16 P.D. 2205.

20 See further Raday, , “The Unprotected Strike” (1977) 12 Is.L.R. 86.CrossRefGoogle Scholar

21 Fleming, 604, 605.

22 Thomson v. Deakin [1952] Ch. 646; Tedeschi, 139.

23 Fleming, 606–607.

24 Ibid., see also Christie, , The Liability of Strikers in the Law of Tort—A Comparative Study of the Law in England and Canada (1967, hereinafter referred to as Christie) 123–124Google Scholar.

25 Fleming, 607; Wedderburn, , The Worker and the Law (2nd ed., 1971), 377.Google Scholar

26 Daily Mirror Newspapers Ltd. v. Gardner [1968] 2 W.L.R. 1239; Square Grip Reinforcement Ltd. v. MacDonald [1968] S.L.T. 65 (Outer House) (No. 2), discussed in Wedderburn, , “The Labour Injunction in Scotland” (1968) 31 Mod.L.R. 550, 552.Google ScholarRideout, , Principles of Labour Law (2nd ed. 1974) 299.Google Scholar

27 National Phonograph Co. v. Edison Bell Ltd. [1908] 1 Ch. 335; G.W.K. Ltd. v. Dunlop Rubber Co. (1926) 42 T.L.R. 375.

28 (1951) 5 P.D. 1559.

29 (1976/77) 8 P.D.A. 421, at 445.

30 [1952] Ch. 646, 686.

31 (1976/77) 8 P.D.A. 421, at 442, 443.

32 It seems that the question of indirect inducement did not arise on the facts of the case in Bauernfreund any more than they did in Eilat-Ashkelon Pipe-Line, since in Bauernfreund the inducement of breach of contract, constituted as it was by inconsistent contractual dealings, was a direct inducement. See Fleming, 605; Christie, 117–118, 123–124; Rideout, , Principles of Labour Law (2nd ed. 1974) 298.Google Scholar

33 This appears to be the view expressed in Tedeschi 139 at 160–161. However, it is not clear whether Professor Tedeschi regards the inclusion of indirect interference as positive law or merely desirable law.

34 See text supra at n. 26.

35 Christie, 117–118.

36 Fleming, 605; Grunfeld, , Modem Trade Union Law (1966) 378Google Scholar (Rideout explains Grunfeld's apparently contradictory requirement that the inducement be both ‘purposive’ and ‘causative’: “This is probably to say no more than that the defendant must intend the breach and that his conduct must be a factor in producing it.“—Rideout, , The Principles of Labour Law (2nd ed., 1974) 299).Google Scholar

37 Tedeschi, 154; Renbit Import v. Langliev (1972) 26 (I) P.D. 17.

38 Eilat-Ashkelon Pipe-Line Case (1976/77) 8 P.D.A. 421, 445.

39 Ibid. at 445.

40 Ibid. at 449.

41 Ibid. at 450.

42 See text infra at nn. 148–155.

43 Bauernfreund v. Drenzer (1951) 5 P.D. 1559; Lindsey and the Baptist Church in Israel v. Shiver (1960) 14 P.D. 2422; Kling, , “Strike Causing Breach of Contract” (1964/65) 21 HaPraklit 542Google Scholar, at 546: Mr. Kling argues that where a strike causes the employer to break his contract with a third party, the third party can bring an action in damages against the strikers: although this would apparently be indirect interference in contract no mention is made of a requirement of unlawful means.

44 See Christie, 153–154.

45 Fleming, 607; see also Wedderburn, , The Worker and the Law (2nd ed., 1971) 377.Google Scholar

46 Rideout, , The Principles of Labour Law (2nd ed., 1974) 302.Google Scholar

47 Ibid., at 301, 302 and see supra n. 26.

48 E.g., Bauernfreund v. Drenter (1951) 5 P.D. 1559: the contract breached was a contract to sell a flat. In other cases also, the nature of the contract breached was not raised as grounds for dismissing an action under sec. 62: Lindsey and Baptist Church in Israel v. Shiver (1960) 14 P.D. 2422; Renbit Import v. Langliev (1972) 26 (I) P.D. 17; Vorziger v. Cadouri (1957/58) 15 P.M.S. 70.

49 Fleming, 604; James v. The Commonwealth (1939) 62 C.L.R. 339, 370; Torquay Hotel v. Cousins [1968] 3 All E.R. 43.

50 As where the Collective Agreement Law, 1957, does not apply to the employment relationship or where the Settlement of Labour Disputes Law, 1957, sec. 37B(b), removes the protection of sec. 19.

51 Electric Wire and Cable Co. Case (1972/73) 4 P.D.A. 122, 132–133; Shitreet and Others v. Maspenot Israel and Others (1972/73) 4 P.D.A. 337, 335.

52 Hebrew University, Jerusalem Case (1973/74) 5 P.D.A. 115 at 119; Eilat-Ashkelon Pipe-Line Case (1976/77) 8 P.D.A. 421 at 444.

53 E.g., W.J. Milnes & Co. v. Electrical Workers Local 349, 476 F 2d. 8. (5th Circ. 1973); U.M.W. v. Osborne Mining Co. 279 F. 2d 716 (6th Cir. 1960).

54 Under the Collective Agreements Law, 1957, a collective agreement can probably be considered a binding contract under secs. 15(a), 16(a); as regards collective arrangements not covered by the Law, the view of the National Labour Court is that such arrangements are not generally “contracts” at all: The Technion and Others v. The Histadrut and Others (1975/76) 7 P.D.A. 313, at 327, 328.

55 In the U.K. Industrial Relations Act, 1971, such a possibility was apparently envisaged since inducing breach of collective agreements was expressly excluded from the unfair industrial practice of inducing breach of contract: sec. 96(3) (a).

56 Tedeschi, 160–161; Renhit Import v. Langliev (1972) 26 (I) P.D. 17; Ladislav v. The Jewish Agency (1960) 14 P.D. 109.

57 Ibid.

58 Ramm, “The Legality of Industrial Actions and the Methods of Settlement Procedure” in Aaron, and Wedderburn, , Industrial Conflict—A Comparative Legal Survey (1972, hereinafter referred to as Aaron and Wedderburn) 255Google Scholar, at 276–279.

59 See for clarification, Raday, , “The Unprotected Strike” (1977) 12 Is.L.R. 86, 110.Google Scholar

60 Thomson v. Deakin [1952] Ch 646, 663, 676–77, 698; Midland Insurance Co. v. Smith (1881) 6 Q.B.D. 561.

61 Grunfeld, , Modern Trade Union Law (1966) 372.Google Scholar

62 Fleming, 607–608 (emphasis added).

63 Cork Industry ‘David & Shot’ v. Alroy (1960) 14 P.D. 177; Vorziger v. Cadouri (1957/58) 15 P.M.S. 70.

64 Tedeschi, 175–176.

65 [1966] 1 W.L.R. 691; followed in Daily Mirror Newspapers Ltd. v. Gardner (1968) 2 W.L.R. 1239.

66 Ibid.. at 701 (emphasis added).

67 Ibid.. at 704.

68 Tedeschi, 176.

69 [1905] A.C. 239, 244, 251, 254–256.

70 Smithies v. Nat. Assoc. of Operative Plasterers [1909] 1 K.B. 310, 337; Read. v. Friendly Society of Operative Stonemasons [1902] 2 K.B. 88, 96; [1902] 2 K.B. 732, 742.

71 Lindsey & Baptist Church in Israel v. Shiver (1960) 14 P.D. 2422.

72 (1958) 12 P.D. 121.

73 Ibid., at 123.

74 Ibid., at 124.

75 Ibid., at 125.

76 Motion 12823/70, 128 68/70, 130/71, Tel Aviv District Court, C.C. 44/71, not published.

77 (1971) 25 (I) P.D. 129.

78 Tedeschi, 139 at 165–166.

79 Ibid.

80 The English judicial and legislative history reveals the bestowal of “trade disputes” immunity in sec. 3 of the 1906 Act; the erosion of that immunity in the courts culminating in Rookes v. Bernard [1964] A.C. 129; legislative reaffirmation of immunity under the Trade Disputes Act, 1965; a limitation of the immunity as regards ‘unofficial’ industrial disputes action in the Industrial Relations Act, 1971; a restoration of trade disputes immunity in the Trade Union and Labour Relations Act, 1974, and the Trade Union and Labour Relations (Amendment) Act, 1976. The 1974 and 1976 Acts have in the view of Denning, Lord “conferred more freedom from restraint on trade unions than has ever been known to the law before”: B.B.C. v. Hearn (C.A.) [1977] I.C.R. 685, 691.Google Scholar

81 See further Simpson, , “‘Trade Dispute’ and ‘industrial Dispute’ in British Labour Law” (1977) 40 Mod. L.R. 16.CrossRefGoogle Scholar

82 (1962) 16 P.D. 2205.

83 (1962) 32 P.M. 14.

84 [1909] A.C. 506.

85 (1962) 16 P.D. 2205, 2212–2214.

86 Ibid. at 2218.

87 Ibid. at 2219.

88 Civil Wrongs Ordinance (Amendment) Law, 1963.

89 Kling, “Strike Causing Breach of Contract” (1964/65) 21 HaPraklit 524.

90 Even under the existing non-interventionist U.K. legislation the limit of ‘trade disputes’ activity is imposed upon the immunity from liability for inducing breach of contract: Trade Union and Labour Relations Act, 1974 sec. 13(1), as amended by the 1976 Act, and see B.B.C. v. Hearn (C.A.) [1977] I.C.R. 685.

91 However, for criticism of the ‘trade disputes’ formula as the proper basis for restricting the liberty to strike see Kahn-Freund, , “Legal Framework” in Flanders, and Clegg, , eds., System of Industrial Relations in Great Britain (1954) 127Google Scholar: “It [the formula] represents a theory of society and politics which, even in 1906, was open to grave doubt and which today is plainly untenable. It rests on the assumption that one can separate economic from political motives.”

92 Bar-Niv, , “More on Strikes as Breach of Contract” (1966) 22 HaPraklit 97.Google Scholar

93 (1971) 25 P.D. 129.

94 Ibid. at 131.

95 In the District Court it had been held that no contractual undertaking between the school and the parents had been proved.

96 See Raday, , “The Unprotected Strike” (1977) 12 Is.L.R. 86, 90–106.Google Scholar

97 Eilat-Ashkelon Pipe-Line Case (1976/77) 8 P.D.A. 421, 444, 452; on the other hand a strike of which statutory notice is not given as required under sec. 5A Settlement of Labour Disputes Law, 1957, does not apparently cease to be a strike: Ramat Gan and Givataim Works Council v. Elko, Electro-Technical Piantine. (1977/78) 9 P.D.A. 113, 135.

98 Settlement of Labour Disputes Law, 1957.

99 In Sec. III infra.

100 (New Version) 1968.

101 (1954) 16 P.E. 100.

102 Criminal Code Ordinance, 1936 as amended by Ordinance No. 37 of 1937: “Any person who does any act which may cause or tend to a public mischief is guilty of a misdemeanour.”

103 Raday, , The Law of Strikes (doctoral thesis, 1975) 574 ff.Google Scholar

104 Motion 1736/77, Mifali Rechev Ashdod Inc. and Others v. Chizick and Others, Haifa District Court, 25/12/77, not yet published.

105 The District Court decided this question in order to determine whether the question before it fell within the exclusive jurisdiction of the Labour Courts under the Labour Courts Law, 1969, sec. 24(a)(1). See supra n. 12 and text following.

106 Erensberg v. Official Receiver (1958) 12 P.D. 121; Kvas v. Minister of Transport (1952) 6 P.D. 1192.

107 Raday, , “The Unprotected Strike” (1977) 12 Is.L.R. 86, 106–111.Google Scholar

108 E.g., strikes which involve a criminal conspiracy under sec. 36 of the Criminal Code Ordinance, 1936.

109 Sec. 43 (1).

110 Sec. 43 (2).

111 For a statement of these requirements for the common law of tort see Fleming, 341, 342.

112 Street on Torts (4th ed., 1968) 234 and, similarly (5th ed., 1971) 234.

113 Grunfeld, , Modern Trade Union Law (1966) 445.Google Scholar

114 Altrasco v. A.G. (1955) 11 P.M.S. 49; Orizeda v. Municipality of Jerusalem (1959) 19 P.M.S. 395.

115 “A public nuisance … confers a cause of action for damages on anyone sustaining personal injury or loss, although no rights or privileges in land of his have been invaded at all”: Fleming, 340.

116 Blumstein v. Council of Bat Yam (1954) 8 P.D. 510; A.G. v. Garnstein (1959) 19 P.M.S. 64; Mekorot Ltd. v. Shaltiel (1968) 22 (I) P.D. 625; Toruna Local Council v. Haimomtch (1967) 58 P.M. 60.

117 See Raday, , “A Cooling-off Period for Israel” (1971) 6 Is.L.R. 569Google Scholar, 578–579.

118 Wedderburn, , The Worker and the Law (2nd ed., 1971) 345Google Scholar, 361–366; Rookes v. Barnard [1964] A.C. 1129; Stratford v. Lindley [1965] A.C. 269. See further Wedderburn, , “The Right to Strike” (1961) 24 Mod.L.R. 572CrossRefGoogle Scholar, (1962) 25 Mod.L.R. 53; “Intimidation and the Right to Strike” (1964) 27 Mod.L.R. 257; Kahn-Freund, , “Rookes v. Barnard—and After” (April, 1964) 14 Federation News No. 40.Google Scholar

119 Trade Disputes Act, 1906, sec. 1; Trade Disputes Act, 1965, sec. 1(1)(a); Industrial Relations Act, 1971, sec. 132(1) (b): Grunfeld, , Modern Trade Union Law (1966) 432–433Google Scholar, 436, 439.

120 Tedeschi, , “Bodily Injuries without the Use of Force and Wilful Negligence” (1967) 23 HaPraklit 170Google Scholar, 185; Rosenthal, , “Does Conspiracy Exist as a Civil Cause of Action in Israel?” in Selected Legal Topics (1958) 401Google Scholar; Levontin, , “Conflict of Laws with Reference to Transnational Contracts” in Israel Academy of Sciences and Humanities Proceedings (1968) vol. Ill (2), p. 41.Google Scholar

121 E.g., Adama Int. Co. in Israel v. Lydia Levy (1956) 10 P.D. 1666; Jadoor v. Slyman (1959) 13 P.D. 916; Viger v. A.G. (1956) 10 P.D. 1246; Esperanta Natan v. Abdulla (1970) 24 (I) P.D. 455; Alkeray v. Balanga & Sons (1950/51) 3 P.M. 93.

122 As expressly required under Art. 46, Palestine Order-in-Council, 1922.

123 See Rosenthal, supra n. 120, at 411.

124 Ibid., at 408.

125 Rookes v. Barnard [1964] A.C. 1429, 1204; Wedderburn, , The Worker and the Law (2nd ed., 1971), 366–367Google Scholar; Grunfeld, , Modern Trade Union Law (1966) 438Google Scholar; Fleming, 621. The importance of this aspect of liability is marginal in view of sec. 12 of the Civil Wrongs Ordinance (New Version), 1968 which imposes liability in torts on those who paritcipate in or authorise commission of a tort.

126 Christie, 86–89; Grunfeld, , Modern Trade Union Law (1966) 440–441.Google Scholar

127 Ibid. See particularly Rookes v. Barnard [1964] A.C. 1129.

128 See text supra at nn. 50–52.

129 Fleming, 619.

130 Mogul Steamship Co. v. McGregor, Gow and Co. [1892] A.C. 25.

131 In England, however, furtherance of collective labour interests such as enforcement of a closed shop or improvement of conditions of employment were not considered “legitimate motive”: Quinn v. Leathern [1901] A.C. 495; Temperton v. Russell [1893] I.Q.B. 715; Trollope v. London Bdg. Trade Fed. (1895) 72 L.T. 342.

132 Fleming, 613; Wedderburn, , The Worker and the Law (2nd ed., 1971) 353–364, 368.Google Scholar

133 Rookes v. Barnard [1964] A.C. 1129. Wedderburn, , “Intimidation and the Right to Strike” (1964) 27 Mod.L.R. 257.CrossRefGoogle Scholar

134 As in the English formula, from the Trade Disputes Act, 1906, sec. 3 to the Trade Union and Labour Relations Acts, 1974 and 1976 sec. 13(1). Strikes or threat of strikes outside the trade disputes sphere are exposed to actions in torts: Wedderburn, in Aaron and Wedderburn, 321 ff.; B.B.C. v. Hearn (C.A.) [1977] I.C.R. 685. At one time a blanket protection was given to trade unions against any form of liability in torts under the Trade Disputes Act 1906, sec. 4 but this was repealed on the Donovan Commission's recommendation that the protection be confined to torts committed in contemplation or furtherance of a trade dispute: Cmnd. 3623, para. 909.

135 In the United States a basic distinction is drawn between direct action and the secondary boycott. The latter was considered a particularly pernicious form of industrial action and hence rendered unlawful by legislation—Labor Management Relations Act, sec. 303(b): “Whoever shall be injured in his business or property by reason [of illegal secondary boycott action] may sue therefor…”. This has been taken in recent cases to include proximate third parties and not only the boycotted person or the primary employer: W.I. Milner & Co. v. Electrical Workers Local 349, 476 F 2d 8 (5th Cir 1973).

136 E.g., under the U.K. Industrial Relations Act, 1971, sec. 96, now repealed, strikes not authorised by a registered union were exposed to tortious liability. In the U.S., strikes called in defiance of the exclusive bargaining representative under the Labor Management Relations Act. 1947 are considered unfair labor practice strikes (the remedies being confined to the collective bargaining parties—see infra n. 141); see Gould, , “The Status of Unauthorised and ‘Wildcat’ Strikes under the National Labor Relations Act” (1966/1967) 52 Cornell L. Q. 672.Google Scholar

137 E.g., German Federal Court doctrine: Ramm, T. in Kahn-Freund, ed., Labour Relations and the Law (1964) 207Google Scholar and in Aaron & Wedderburn 295, 328.

138 Eilat-Ashkelon Pipe-Line Co. Case (1976/77) 8 P.D.A. 421, 442.

139 Emergency laws are the primary example of “public administrative restrictions” on the strike: see Wedderburn in Aaron & Wedderburn, 342–364. Certain kinds of restriction on public employees' strikes may also fall into this category: loc. cit. 364–377.

140 See supra nn. 135, 136, 137, 138.

141 The concept of unfair labour practices under Labor Management Relations Act, 1947 may be analoguous—see supra n. 136. See also Teamsters Union v. Lucas Flow (1962) 369 U.S. 95; Maestro Plastics Corporation v. N.L.R.B. (1956) 350 U.S. 270.

142 See supra n. 138. This seems to be the kind of limitation on the iiberty to strike imposed in the public services by the legislature: Settlement of Labour Disputes Act, 1957, sec. 37A. It also appears to be the kind of limitation imposed by the National Labour Court on strikes or disputes of rights: Electric Wire and Cable Co. Case (1972/73) 4 P.D.A. 122, 134; Hebrew University Jerusalem Case (1973/74) 5 P.D.A. 115, 131.

143 Sec. 303 of the Management Labor Relations Act was adopted to prevent exertion of secondary pressure on neutral employers on the grounds that “many small businesses had suffered severe economic hardship as a result of labor disputes in which they played no responsible role”, (emphasis added): “Labor Management Relation Act sec. 303” (1974) 87 Harv. L.R. 876, 877. Morris, Charles, The Developing Labor Law (1971) 635.Google Scholar

144 Eilat-Ashkelon Pipe-Line Case (1976/77) 8 P.D.A. 421, 456–458.

145 Thus the same problem of fixing the extent of liability exists under sec. 303 Labor Management Relations Act which bestows standing upon a person “injured in his business or property” by secondary boycotts; various tests of ‘proximate injury’ have been suggested: in UMW v. Osborne Mining Co. 279 F 2d 729 (6th Cira); 364 U.S. 881 (1960), a “remoteness” test was applied: in W.J. Milner & Co. v. Electrical Workers Local 349, 476 F 2d 8 (5th Circ. 1973) a “case by case analysis” was preferred.

146 B.B.C. v. Hearn (CA.) [1977] I.C.R. 685: per Lord Denning M.R. at 693: “There was not a trade dispute ‘in contemplation’… it means that the trade union and its officers are not exempt from the ordinary rule of law—which is that men must honour their contracts and not interfere with the performance of them.”

147 Pound, , Jurisprudence (1959) vol. 4, p. 148.Google Scholar

148 Loewe v. Lawlor 52 L.Ed. 488, (1907) 208 U.S. 274 (1915) 209 F 721, 235 U.S. 522; Morris, Charles, The Developing Labor Law (1971) 6.Google Scholar

149 Sweden: Act respecting Collective Agreements, 1927, amended 1945, secs. 8, 9; Germany: Aaron & Wedderburn, 311.

150 U.S.: National Labor Relations Act, sec. 301(b); Morris, Charles, The Developing Labor Law (1971) 642.Google Scholar The provisions of the Settlement of Labour Disputes Law, 1957, as they stand at present, would present an obstacle to adoption of such an approach in the public services which are governed by secs. 37A—37E of the Law. Sec. 37B (d) provides that employees' organisations will not be held liable for unprotected strikes which they did not call or authorise and that their own certification to this effect will be conclusive evidence of the absence of authorisation. For criticism of the certification provisions in the section, see Raday, , The Law of Strikes (doctoral thesis, 1975) 808–812.Google Scholar

151 Eilat-Ashkelon Pipe-Line Case (1976/77) 8 P.D.A. 421.

152 Ibid. at 455.

153 Ibid. at 456.

154 Ibid. at 456.

155 Ibid.

156 E.g., Collective Agreements Law, 1957, secs. 15, 16, 19, 20, 22; Settlement of Labour Disputes Law, 1957, sec. 37A. 458.