The right to strike is protected in terms of section 23(2)(c) of the Constitution of the Republic of South Africa, 1996 (the Constitution). The Labour Relations Act 66 of 1995 (the LRA) regulates this right in terms of its section 64. The LRA defines a strike in section 213 and goes further to provide for a secondary strike (also known as a "sympathy strike") in section 66. Given the concept of secondary strike as provided for in the LRA, an ordinary strike is usually referred to as a "primary strike" (Du Toit, Godfrey, Cooper, Giles, Cohen, Conradie and Steenkamp Labour Relations Law: A Comprehensive Guide 6ed (2015) 361; Van Niekerk, Smit (eds), Christianson, McGregor and van Eck Law@work (2019) 465). A primary strike is by employees who have a dispute with their employer, which relates to "matters of mutual interest or terms and conditions of employment" (Manamela "Matters of mutual interest for purposes of a strike - Vanachem Vanadium Products (Pty) Ltd v National Union of Metalworkers of South Africa 2014 9 BLLR 923 (LC)" 2015 Obiter 791-800; NUMSA obo Members v SAA 2017 38 ILJ 1994 (LAC)). These employees engage in strike action to pursue their demands or grievances which are directed against their employer (Grogan Collective Labour Law 3ed (2019) 292). A secondary strike is by employees in support of other employees who are engaged in a strike against their employer. Employees of the secondary employer therefore support striking employees of the primary employer, even though they have no material interest in the matter that gives rise to the primary strike. This is based on the assumption that if a business is connected to another one, then if employees of the former engage in strike action, the strike will have an impact on the functioning of the latter, which will be forced to accede to demands by its employees.