This is an application to the Council of Appeal for leave to appeal to the Judicial Committee of the Privy Council. The reason is that "the appeal raises matters of great general or public importance.".

The motion also sought a stay of the Court of Appeal decision pending the determination the Privy Council.

This 281 page document sets out the arguments and rationale behind the application.

This is the response on behalf of the Union resisting the Motion for leave to go to the Privy Council