Conway v Wade

inducing dismissal | definition of 'contemplation or furtherance of a trade dispute' under the Trade Disputes Act 1906

In Conway v Wade [1909] AC 506 HL, the House of Lords held that a jury was entitled to find that the conduct of an individual in attempting to induce an employer to dismiss an employee was not conduct in 'contemplation or furtherance of a trade dispute' and provided guidance as to the meaning of those words.

The facts found by a jury were as follows: Conway was employed by Readhead & Sons; Wade was a union man; Wade had considered that Conway owed a fine to the union; in an effort to compel Conway to pay the fine and to punish him for not having done so, Wade procured Readhead & Sons to dismiss Conway by threatening that union members in Read-head & Sons' employ would strike unless Conway was dismissed; Conway quit his employment as a consequence; the threat by Wade that union men would strike was not true.