T HE apparent history of legal development in the area of labourmanagement economic conflict is, on the face of it, one of policy and counter policy. Judicial proscription during the earlier stages was followed by forms of amelioratory legislation. Currently, emerging recognition in the decisions of the further implications of union objectives, amounting frequently to entire endorsement, is being followed by apparently experimental legislative attempts to channelize and delimit union economic action utilized in their furtherance. It would be naive to suggest that the concern in the decisions, consciously or otherwise, has not been with the implementation of policy. And it is, accordingly, too bad that the inability of general legislative forms, particularly of prohibition, to supply complete solutions in individual cases has not been balanced by a demonstration by the courts concerned with individual cases of a capacity or willingness to provide an adequate basis for policy formulation. The complex of factors entering into individual situations in the labour-management context, and the varying implications of those differing situations in a community context, demanded, and will continue to demand to an increasing degree, specialized investigations and solutions. But the earlier decisions, concerned essentially with deprivations following on union economic action, and many of the more recent decisions, concerned actually with the fulfilment or maximization aspect of union activity, have been concerned almost entirely with the description and internal reconciliation of the purportedly applicable legal theory. The legal theory of Canadian labour decisions concerned with union objectives and economic methods must be sought in three quarters: a background of natural law individualism, a laissez-faire hypothesis, and the doctrinaire approach of Austinian positivism. The significant contribution of the natural law philosophy, in the context of the present study, has been an emphasis on the individual. It asserted the existence in the individual of certain qualities of free will and freedom to act-in the present context, freedom in the disposition of labour and capital. The division of significant social units, between the state and the individual on the one hand, and between individuals on the other, provided fixed frames of reference. Group organization and group action within the state did not fit easily into that scheme. Further, recognition of the acquisitive instinct-a postulate of natural rights theory-was coupled with the nineteenth-century preference for a free and open market to find expression in a doctrinaire assertion of