comprehensively resolved by the Australian Industrial Relations Commission's landmark decision on 21 March 2005: the Schefenacker, the Murray Bridge and the La Trobe University certified agreements (the three certified agreements case). The decision determined what provisions the Commission would allow to be certified in enterprise agreements. The decision was generally considered as a union victory, as it endorsed a whole raft of union friendly clauses. One final consequence of the case of Electrolux v AWU is that it upheld several previous decisions of the High Court, which had decided that provisions allowing for payroll deductions of union dues did not "pertain to the relationship between employer and employee." Payroll deductions were consequently prohibited from being placed into enterprise agreements and so cannot be placed into enterprise agreements created under the WorkChoices reforms. The relevance of Electrolux v AWU as an authority in Australian industrial relations in many ways ceased, with the introduction of the WorkChoices legislation reform package. However, consistent with the litigation itself, it was the consequent events that remained relevant. The decision of the three certified agreements case is still an applicable authority in determining what can and cannot be placed in an enterprise agreement. References High Court of Australia cases 2004 in Australian law Electrolux 2004 in case law Australian labour case law