The House of Lords, acting as the highest court of appeal, held that the threat of strike action was unlawful intimidation.

Civil law had been one of the main tools employers used against unions in their early days until the Trade Disputes Act 1906 gave unions immunity from certain torts (including conspiracy) when taken in pursuit of an industrial dispute.

As a result, the Labour government of Harold Wilson introduced legislation to restore the status quo from before the case.

[3] The Conservatives sought to amend the legislation to exclude the protection if the dispute was regarding the continued employment of an individual.

The closed shop was eroded by the Conservative government in the 1980s and eventually banned by the Employment Act 1990.