Employment analysis: Under section 230 of the Trade Union and Labour Relations (Consolidation) Act 1992 (TULR(C)A 1992), union members must be allowed to vote in a ballot for industrial action without ‘interference’ by their union. If this requirement is not met then the union risks losing its statutory immunity against tortious liability (eg for inducing a breach of contract). In this context, ‘interference’ means conduct, whether by words or action, which has the effect of preventing, or hindering, the ordinary course of the voting process. It is not limited to conduct which amounts to intimidation, coercion, fraud or the like, according to the Court of Appeal.