## Facts

- Multiple South Wales colliery owners employed miners under service contracts requiring notice before stopping work.
- Miners’ wages were set by a sliding-scale arrangement that rose or fell with the price of coal.
- With coal prices declining, a registered trade union (the South Wales Miners’ Federation) sought to restrict output to support coal prices and wages.
- The union’s council ordered a “stop-day” (a general holiday/cessation of work) on November 9, 1900, and communicated the directive across the coalfield.
- More than 100,000 miners complied, abstaining from work without giving the contractually required notice, thereby breaching their employment contracts.
- A subsequent conference authorized the union’s council to declare further general holidays when it considered them necessary to protect wages and the industry.
- The union acted to protect members’ wages and was found to have acted honestly, without malice or ill-will toward employers.
- The colliery owners sued the union and its officers for procuring breaches of contract (and alternatively for conspiracy), seeking damages for resulting losses.

## Issues

1. Whether a trade union commits an actionable tort by intentionally procuring workers to breach employment contracts, even if the union acts honestly and without malice to protect wages.
2. Whether an economic objective of supporting coal prices and wages constitutes legal justification for interference with employers’ contractual rights.

## Decision

- The House of Lords dismissed the union’s appeal and affirmed judgment for the employers.
- The court held that intentionally procuring a breach of contract is actionable unless the defendant proves legal justification.
- The union’s honest purpose of advancing members’ interests and lack of spite toward employers did not amount to legal justification.
- Damages were available against the union and its officers for losses caused by the induced contractual breaches.

## Legal Principles

- Knowingly and intentionally procuring another party’s breach of contract is a tort, subject to a defense of legal justification.
- Absence of malice, good faith, or a desire to advance the defendant’s (or members’) economic interests does not, by itself, justify intentional interference with contractual performance.
- A defendant asserting justification bears the burden to show a legally sufficient basis for interfering with the claimant’s contractual rights.

## Conclusion

The House of Lords held the trade union liable for directing a mass work stoppage that induced miners to breach their employment contracts, ruling that a good-faith, wage-protection motive does not legally justify intentional interference with contractual rights.


Glamorgan Coal Co. v. S. Wales Miners’ Fed’n, [1905] A.C. 239 (H.L.)