Production at the Rustenburg mine was disrupted for eight weeks in 2012 following illegal strike action.
That might help explain why New York City's transit workers were willing to wage an illegal strike last month.
"Equivalent refined platinum production decreased by 29% owing to the illegal strike action at the Rustenburg, Amandelbult and Union mines, " the company said in a statement.
After workers allied with the AMCU went on an illegal "wildcat strike" at Lonmin, police have unsuccessfully tried to get them to return to the mine.
Employing extra people to do the work of staff who are on strike is illegal under employment law.
Lawyers for the board issued a memorandum rejecting a complaint brought by a group of 20 private bus companies who argued the strike was illegal.
Officials at the plant said the strike was illegal because those taking part were occupying the production line and blocking non-strikers from entering the building.
The world's third-largest producer of platinum said the strike was illegal.
The justice secretary, Jack Straw, has threatened to make it illegal for prison officers to strike unless the agreement is reinstated.
Even though their strike was nominally illegal, polls suggested that popular support for the nurses fluttered around 70%, and there is near-universal agreement that they are underpaid.
Given that plans for a 12-day Christmas strike were also deemed illegal, one could start to question Unite's procedures.
He said members had not been balloted for strike action, so any participation would be illegal.
Because it's illegal for public employee unions in New York state to strike, the 2005 work stoppage led to a range of sanctions from which the TWU is still recovering.
It is, however, very unlikely the courts would strike down any effort by Congress to prohibit illegal residents from working or obtaining welfare benefits, including federal efforts to solicit or entice the states to cooperate in such efforts through the use of federal grants and mandates.
After that was ruled illegal in June, Guidant was left with few options: strike a deal with Boston Scientific, buy Cook, find a viable way around the ruling or sit out the market until its second-generation product was approved.
Reliever Hugh Casey delivers a sinker (some say illegal spitball) to Yankee batter Tommy Henrich, who swings and misses for strike three.
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