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QUINN V. LEATHAM

Quinn v. Leatham [1901] UKHL 2

ISSUE:

  • Whether the defendants had wrongfully conspired to injure the plaintiff’s business by inducing his customers not to do business with him?

RULE:

  • It is unlawful to conspire to injure another person’s business, even if the means used to achieve that end are not unlawful in themselves.

FACTS:

  • The plaintiff, Henry Leatham, was a butcher in Lisburn, Ireland.
  • The defendants, Joseph Quinn and others, were members of the Belfast Journeymen Butchers and Union Assistants’ Association (the BBA).
  • The BBA was a trade union that represented butchers in Belfast.
  • Leatham had refused to employ a butcher who was a member of the BBA.
  • In response, the BBA called a strike of all its members who were working in Lisburn.
  • The BBA also induced Leatham’s customers not to do business with him.
  • As a result of the BBA’s actions, Leatham suffered a significant loss of business.

HELD:

  • It is unlawful to conspire to injure another person’s business, even if the means used to achieve that end are not unlawful in themselves.
  • The right of workers to strike is not unlimited and unions could be held liable for conspiracy to injure another person’s business if they used unlawful means to achieve that end.
  • Unlawful means that could be used to injure another person’s business include:
  • Threats of violence or intimidation
  • Blacklisting
  • Inducing a breach of contract
  • Passing off
  • Misleading advertising
  • If a person or group of people conspire to use unlawful means to injure another person’s business, they may be liable for the tort of conspiracy.
  • The victim of the conspiracy may be able to sue for damages, including lost profits and reputational damage