R v CAC ex p BTP Tioxide Ltd

Union U had entered into a limited bargaining agreement with P. U requested info regarding the job evaluation process, which was not covered in the agreement between P and U. P refused. High court held that P 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”.