Rigby v Connol

Rigby v Connol 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 It is no longer good law, having been superseded by Lee v The Showmen’s Guild of Great Britain and the Trade Union and Labour Relations (Consolidation) Act 1992.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’ would be fined £5 and entitled to no union benefits until the fine was paid. Rigby broke the rule and was expelled.

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.