Under common law, Ford v. A.U.E.F. , , the courts found once that collective agreements were not binding. Second, the Industrial Relations Act, introduced by Robert Carr (Minister of Labour in Edward Heath`s office), provided in 1971 that collective agreements were binding, unless a written contractual clause indicated otherwise. Following the fall of the Heath government, the law was struck down to reflect the tradition of the British labour relations policy of legal abstention from labour disputes. The Court also clarified that freedom of association means that an individual has the right to develop his own beliefs rather than let him be thwarted by the state. For example, unions are prohibited from using non-member money to revive an ideological cause that has nothing to do with the union`s duties as an agent. The right to collective bargaining is recognized by international human rights conventions. Article 23 of the Universal Declaration of Human Rights describes the ability to organize fundamental human rights unions.  Point 2 (a) of the International Labour Organization`s statement on fundamental principles and rights in the workplace defines „freedom of association and effective recognition of the right to collective bargaining” as an essential worker`s right.  The 1948 Convention on Freedom of Association and the Protection of the Right to Organization (C087) and several other conventions protect collective bargaining in particular by creating international labour standards that deter countries from violating workers` right to co-association and collective bargaining.
 In Sweden, about 90% of employees are subject to collective agreements, compared to 83% in the private sector (2017).   Collective agreements generally contain minimum wage provisions. Sweden does not have legislation on minimum wages or legislation extending collective agreements to disorganised employers. Unseated employers can sign replacement agreements directly with unions, but many do not.