Following Taff Vale, unions were held to be quasi-corporations under the Trade Union Acts of 1871 and 1875, with the capacity in civil law to sue and be sued.2 Consequently, as a union could be sued in its own name, injunctions could formally bind the union itself. More seriously, Taff Vale opened up the possibility of union bankruptcy as their funds were now put at risk by employers pursuing large damages claims for the effects of industrial action. The intervention of the law in the guise of the Trades Disputes Act 1906, which was passed in direct response to Taff Vale, gave trade unions total immunity from any action in tort3 and partial immunity to individuals where the action taken was ‘in contemplation or furtherance of a trade dispute’.4