R. M. Brown

The union filed a complaint alleging the employer violated section 43(1) of the Labour Relations Act by failing to deduct union dues for all employees in the bargaining unit.

The parties' first collective agreement only required dues deductions for employees who signed an authorization form.

The employer argued that a request under section 43(1) could only be made during collective bargaining, not during the term of an agreement.

The Board held that section 43(1) can be invoked during the life of a collective agreement and directed the employer to comply with the union's request to deduct and remit regular union dues.