business relies, retailers who sell its products, physical premises with shared management or majority shareholders (sister/allied premises) and homes of any of the latter persons. In most jurisdictions, secondary pickets lack all or many of the civil law protections given to primary pickets. For example, at the Battle of Saltley Gate in 1972 in England, striking miners picketed a coke works in Birmingham and were later joined by thousands of workers from industries locally. Secondary picketing has been illegal (in the sense that, unlike lawful picketing, it may give rise to a cause of action in tort) in the United Kingdom since the coming into force of section 17 of the Employment Act 1980, a law tabled and passed by the Conservative government of Margaret Thatcher. Labour sought repeal of this via the party's 1987 manifesto; the party called for a debate on such issues in the next (1992) manifesto; and dropped this position under Tony Blair and later leaders' manifestos from 1997 onwards. Another tactic is to organise highly mobile pickets, who can turn up at any of a business's locations quickly. These flying pickets are particularly effective against multi-facility businesses that could otherwise pursue legal prior restraint and shift operations among facilities if the locations were known with certainty ahead of time. The first highly strategic use of such may have been the example of the 1969 miners' strike in Britain. Flying pickets are usually not legal in the United Kingdom; workers must only picket at their workplace. Picketing can interweave with boycotting campaigns by pressure groups across the political and moral spectrum. In particular religious groups such as the Westboro Baptist Church seek to picket local store fronts and events they consider sinful. Non-employee protesters are third parties to the business so counter-actions may lie in the courts (or out-of-court remedies) for disruption of trade, unlawful protest, defamation, and certain types of illegal advertising, trespass and nuisance, against which freedom of expression, of religion and/or a public interest defense vie. Different jurisdictions weigh these two competing sets of rights differently. The global result is the rules and outcomes are fact-sensitive (rest closely on the actions, form, subject-matter, duration and behaviors) and law-sensitive (divergently regulated or governed by case law). Disruptive picketing Disruptive picketing covers a wide variety of pickets: Obstructive picketing which significantly physically narrows or stalls the flow of persons, goods or services into and out