ABSTRACT
The analysis of the role of legislation in the formation of the three principal models of trade unionism existing in Europe in the late nineteenth century immediately raise very important theoretical issues which raise some doubts about the possibility of carrying out such a comparative study of Germany, France and England. The legal status of the trade unions in Britain was established by the Trade Union Act, 1871. It safeguarded union members from legal action for being 'a restraint of trade', protected the unions from legal interference in their internal affairs, safeguarded their funds and permitted them to come within the scope of Friendly Society legislation. In France, the law Waldeck-Rousseau, 1884, established trade union law. The German trade unions were expected to fit in with the general laws dealing with associations. At first these were variable, their nature depending on the region of Germany. Unified legislation did not occur until 1908.
