Employment – Unfair dismissal. As a matter of domestic law, members of local authority park police forces were employed in 'police service' and thus prevented by the Employment Rights Act 1996 s 200 from pursuing claims for unfair dismissal. Their trade unions, the third appellants, could however bring claims for a protective award in respect an alleged failure in collective consultation as the provisions of the Trade Union and Labour Relations (Consolidation) Act 1992 s 280, construed so as to give effect to rights under European Convention on Human Rights art 11. In so deciding the Court of Appeal, Civil Division affirmed in part the decision of the Employment Appeal Tribunal.