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Comparative study of the relationship between trade unions and their members is obviously of greatest difficulty. In most countries there is relatively little positive law either in the form of judicial decisions or statutes, for the traditional and deeply rooted conception of unions as private voluntary associations strongly discourages law making concerning their internal affairs. Indeed, one of the dominant themes running through all of the national reports is that in a democratic society unions should be self-governing. Although in Great Britain there are a substantial number of court decisions, and in the United States many decisions and now a most significant statute--the Labor Management Reporting and Disclosure Act (LMRDA)-the positive law largely reinforces rather than denies this theme of union self-government.
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