employee considers that he has been dismissed, or has suffered action short of dismissal, in contravention of these rights he may complain to an industrial tribunal, which has the power to award substantial compensation or, where appropriate, order reinstatement. Legislation does not define what constitutes action short of dismissal, and it would be for an industrial tribunal to decide whether an employee had suffered such action. Action short of dismissal might, for example, cover discrimination in promotion, transfer or opportunities for training, or threats of dismissal or redundancy. Irade„union membership and activities 284. The Trades Union Congress (TUC) presented a complaint to the International Labour Organisation (IL0) in February 1984 (case No. 1261) that the United Kingdom had violated articles 2, 3, 4 and 5 of the IL0 Freedom of Association and Protection of the Right to Organize Convention, 1948 (No. 87), by denying staff employed at the Government Communication Headquarters (GCHQ) the right to belong to a trade union. 285. The Committee on Freedom of Association found that the action taken by the Government was not in conformity with Convention No. 87. However, the Government contends that Convention No. 87 cannot be viewed in isolation from Convention No. 151, which provides (in article 1.2) that the scope of the Convention's application to staff whose duties are of a highly confidential nature shall be decided by national laws and regulations. The IL0 Committee of Experts has acknowledged that complex legal issues are involved in the interrelation of the conventions. The Court of Appeal in the United Kingdom has taken the view that article 1.2 of Convention No. 151 takes precedence over Convention No. 87. Accordingly, the Government does not consider that its actions at GCHQ represent a breach of its obligations under Convention No. 87. CCPR/C/58/Add.6 page 64 
**Analysis**
The text appears to be related to labor rights and employment law, specifically discussing the rights of employees to union membership and protection from unfair dismissal. The text also references international labor conventions and the application of national laws to these conventions.

**Category**
Employment