The history of the trade union can be seen to have begun in the Industrial Revolution, where the rise of factories and the deskilling of labour led to workers seeking security through collective bargaining agreements. However, these early efforts at unionisation were generally deemed to be illegal, and punished by imprisonment or ‘transportation’ to the colonies, such as in the case of the Tolpuddle Martyrs (Webb and Webb, 1976, p. 23). However, in the nineteenth century many of the laws that prevented the formation of unions were repealed. As a result, trade unions grew rapidly, supported by the passage of further laws such as the 1906 Trade Disputes Act, which protected employees from being sued for going on strike, provided their strike was carried out by a trade union and met certain rules (Beckett, 2001, p. 22). Indeed, as of the present day, trade unions are the only accepted vehicle through which industrial action can occur.