unions was based in contract, and the rights of members depended on being able to show some proprietary interest to be specifically enforced. This meant that the express terms of the union rule book can, like any contract, be supplemented with implied terms by the courts as strictly necessary to reflect the reasonable expectations of the parties, for instance, by implying the Electoral Reform Service's guidance to say what happens in a tie break situation during an election when the union rules are silent. If there are irregular occurrences in the affairs of the union, for instance if negligence or mismanagement is not alleged and a majority could vote on the issue to forgive them, then members have no individual rights to contest executive decision making. However, if a union's leadership acts ultra vires, beyond its powers set out in the union constitution, if the alleged wrongdoers are in control, if a special supra-majority procedure is flouted, or a member's personal right is broken, the members may bring a derivative claim in court to sue or restrain the executive members. So in Edwards v Halliwell a decision of the executive committee of the National Union of Vehicle Builders to increase membership fees, which were set in the constitution and required a ⅔ majority vote, was able to be restrained by a claim from individual members because this touched both a personal right under the constitution and flouted a special procedure. Discipline and expulsion ASLEF v United Kingdom [2007] ECHR 184 McVitae v UNISON [1996] IRLR 33 Roebuck v NUM (Yorkshire Area) No 2 [1978] ICR 676, Templeman J Esterman v NALGO [1974] ICR 625, Templeman J Radford v NATSOPA [1972] ICR 484, Plowman J Dispute resolution Hamlet v GMBATU [1987] ICR 150, Harman J Longley v NUJ [1987] IRLR 109 Union members' rights Trade Union and Labour Relations (Consolidation) Act 1992 ss 28–31, true and fair view of accounts, member's right to inspect, and complaints to Certification Officer. Trade Union and Labour Relations (Consolidation) Act 1992 ss 62–65, right to require a ballot before industrial action, and no detriment may follow Knowles v Fire Brigades Union [1997] ICR 595 Edwards v Society of Graphical and Allied Trades [1971] Ch 354 Cheall v APEX [1983] 2 AC 180 Trade Union and Labour Relations (Consolidation) Act 1992 s 174 ASLEF v United Kingdom [2007] ECHR 184 Amalgamated Society of Railway Servants v