Union U had entered into a limited bargaining agreement with Plaintiff.
U requested info regarding the job evaluation process, which was not covered in the agreement between Plaintiff and U. Plaintiff refused.
High court held that Plaintiff didn’t have to disclose because the info wasn’t to be used to enable U to carry out a representational function (as it couldn’t make representations on this subject under the agreement.
The legislation (s.181- above) restricted itself to “matters in respect of which the union was recognised”.