Rigby v Connol

Rigby v Connol (1880) 4 Ch D 482 is a UK labour law case, concerning the right of a union member not to be expelled. It is no longer good law, having been superseded by Lee v The Showmen’s Guild of Great Britain 2 QB 329 and the Trade Union and Labour Relations (Consolidation) Act 1992.

Facts Rigby wanted a declaration and injunction to prevent his expulsion from a union that operated a closed shop. The rules of the "Journeymen Hatters' Fair Trade Union of Great Britain and Ireland", registered under the Trade Union Act 1871, said any journeyman whose son worked for a ‘foul shop’ (one where non-union workers were employed) would be fined £5 and entitled to no union benefits until the fine was paid. Rigby broke the rule and was expelled.

Judgment Lord Jessel MR held that a union member’s right is founded on property, and because the member had disclosed no proprietary interest in the union in his statement of claim, he could not succeed.

See also

UK labour law

Notes

References