Union recognition: Employee bound by agreement made with shop steward

In Harris v Richard Lawson Autologistics Ltd 2002 [IRLR] 476, the Court of Appeal holds that a shop steward had apparent or ostensible authority to negotiate an agreement on holiday pay on behalf of TGWU members he represented, notwithstanding that, on the assumed facts of the case, the agreement was not put to the members, and was concluded in contravention of TGWU standing instructions. As a result, the employee, a TGWU member, was bound by the agreement, which had the effect of reducing his holiday pay.