Pre-Action Letter (Part 1) to the Labour Party's National Executive Committee (NEC) about the Newham Trigger Ballot results and the five grounds of claim: 1. Rules inconsistently applied in respect of which Affiliated Organisations (AOs) could take part; 2. Rules were inconsistently explained; those running the Trigger Ballot (TB) failed to ensure AOs were properly informed of voting rights and that TB was fairly run; 3. NEC failed to carry out a proper investigation, despite prima facie evidence of impropriety (as set out in NEC letter sent on 17 January 2017) 4. NEC endorsed Sir Robin Wales when there was strong evidence that process was flawed; 5. Rules wrongly applied: some AOs were allowed to vote more than once. Litigants asked the NEC to: 1. Order a new and open selection process and/or 2. Carry out a full and proper investigation and/or 3. Declare the previous TB process void and hold a new one The letter also made clear that if the Labour Party was prepared to withdraw endorsement of Sir Robin Wales, then litigants would wait till after the general election 2017 for a reply on the other matters raised. Sought reply within 14 days.

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Pre-action letter before claim
Dear Sir / Madam
Newham Mayoral Trigger Ballot – December 2016
1. We have been instructed by a number of members of the Labour Party in the London
Borough of Newham (“Newham”), including Mr David Gilles and Mr John Saunders. Please
find an authority to act for Mr Gilles enclosed for reference.
2. We write further to two letters of 31 October 2016 and 17 January 2017 sent by various party
members in Newham outlining their concerns in connection with the ‘trigger ballot’ procedure
in Newham, to select the Labour Party candidate for the directly elected mayoral election.
Please treat this as a Letter Before Action, for the purposes of the Pre-Action Protocol in the
Civil Procedure Rules. Given the urgency of this matter, we request that you respond within
14 days, by 29 May 2017.
3. In summary, and as set out more fully below, our clients have instructed us to write to you
setting out their concerns about the flawed nature of the trigger ballot procedure in Newham
in December 2016. The trigger ballot process was not conducted in accordance with the
Our ref: RAN/28067
The General Secretary and the National
Executive Committee
The Labour Party
Labour Central
Kings Manor
Newcastle upon Tyne
NE1 6PA
First by email
15 May 2017

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December 2012 Labour Party Procedural Rules for re-selection of Democratically Elected
Mayors (“the Procedural Rules”) or the Labour Party Rule Book 2017 (“the Rule Book”).
In particular:
1) Ground 1: The Procedural Rules were inconsistently applied (in respect of the basis
on which affiliated organisations could participate in the selection process);
2) Ground 2: The Procedural Rules were inconsistently explained (the Procedures
Secretary failed to ensure that the various affiliated organisations were properly
informed as to their voting rights and to ensure that the procedure was conducted
fairly).
4. Either of these breaches alone are sufficient to render the trigger ballot procedure unlawful.
5. In addition, following what we contend to be an unlawful trigger ballot, in breach of the Rule
Book and its associated guidance, the National Executive Committee of the Labour Party
(“NEC”):
1) Ground 3: Failed to investigate the improper nature of the trigger ballot procedure (in
the face of, to say the least, prima facie evidence that the process was flawed); and/or
2) Ground 4: Unlawfully endorsed the nomination of Sir Robin Wales (in the face of the
strong prima facie evidence that his reselection had been flawed).
6. Ground 5: Additionally, the Procedural Rules were incorrectly applied (inter alia because
some affiliated organisations were allowed to vote more than once (see also the matters set
out in the letter of 17 January 2017)).
7. Unless the NEC indicates its intention to take the steps at paragraph 60 – 61 of this letter,
our clients intend to seek declarations set out below.
8. For the avoidance of doubt, our clients wish to underline that this proposed claim should not
be understood as an indication of any personal animus on the part of any of the prospective
Claimants against Sir Robin Wales himself. Their concern is purely to ensure the integrity of
the selection process whereby the directly elected mayoral candidate in Newham is
selected.

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I. Party details
9. We have been instructed by members of the Labour Party in Newham, including David Gilles
and John Saunders.
10. All of the prospective Claimants (“the Claimants”) are current members of the Labour Party
who reside in Newham. Their membership payments are up to date.
11. The Labour Party is an unincorporated association. The various rules and procedures of the
Labour Party (as published) form a contract between the NEC and its membership.1
The
Party Rules provide:
“In furtherance of its primary purpose and key functions, the duties and powers of the NEC shall
include:
to uphold and enforce the constitution, rules and standing orders of the Party and to take any
action it deems necessary for such purpose, including disaffiliation, disbanding, suspending or
otherwise disciplining any affiliated organisation or Party unit; in furtherance of such duties it
shall have the power to suspend or take other administrative action against individual members
of the Party subject to the provisions of the disciplinary rules set out in Chapter 6 below of these
rules.
…
For the avoidance of any doubt, any dispute as to the meaning, interpretation or general application
of the constitution, standing orders and rules of the Party or any unit of the Party shall be referred to
the NEC for determination, and the decision of the NEC thereupon shall be final and conclusive for
all purposes.”2
12. The powers of the NEC include the power to investigate alleged abuses of the party rules:3
II. Background facts
13. The background facts have been set out in a detailed letter to the NEC on 17 January 2017.
A copy of that letter is enclosed herein. The pertinent facts are set out in summary below.
The Nomination Process
14. Between 25 October 2016 and 4 December 2016 the Labour Party in Newham held an
affirmative nomination process (“the Nomination Process”) for the reselection of the
incumbent Mayor of Newham as the Party’s candidate in the May 2018 Mayoral election. Sir
Robin Wales, a Labour party member, is the incumbent directly elected mayor. The purpose
of the Nomination Process was to identify whether or not he should face internal competition
1
Choudhry v Treisman [2003] EWHC 1203; Evangelou v McNicol [2016] EWCA Civ 817 per Lord Justice Beatson at ¶19.
2
Party Rules Chapter 1 Clauses VIII(3) and X(5).
3
Party Rules Chapter 6 Clause I(A).

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via an “Open Selection” allowing other candidates to stand, or be automatically nominated
as the Labour Party candidate.
15. The Nomination Process was to be conducted in accordance with the Procedural Rules.
They provide, where relevant4
:
“To be reselected, the sitting directly elected Mayor will require a majority of the affirmative
nominations from affiliated organisations, Labour party branches or forums that comprise the
electoral area (London borough) covered by the Mayor. Where this is the case the sitting directly
elected Mayor will be deemed reselected, subject to NEC endorsement.
If the sitting directly elected Mayor fails to obtain a majority of the affirmative nominations then a full
selection procedure will take place in the electoral area covered by the Mayor.
….
3.1 Organisations entitled to make an Affirmative Nomination
The affiliated organisations entitled to make an affirmative nomination are those affiliated to any
CLP with a geographical interest in the electoral area (London borough) as at 31 December of the
previous year. Each affiliated organisation is entitled to make one affirmative nomination only
even if it is affiliated to more than one CLP with a geographical interest in the electoral area
(London Borough).”
16. The Procedural Rules also allow for the appointment of a Procedures Secretary. Patrick
Murphy was appointed as the Procedures Secretary for the Nomination Process.
17. On 26 October 2016, Mr Murphy wrote to the Labour Campaign Forum (“LCF”) members to
inform them of the timetable and process for the selection of the directly elected Mayor. He
wrote:
“The freeze date for members to participate in the process is 25 October 2016.
…
Affiliated organisations eligible to make an affirmative nomination are those that have been affiliated
to any CLP with a geographical interest in the electoral area at least 60 days prior to the freeze
date. Each affiliated organisation is entitled to make one affirmative nomination only, even if it is
affiliated to more than one CLP with a geographical interest in the electoral area.”
18. On 28 October 2016 Mr Murphy wrote to Mariam Dawood and Alan Griffiths, the secretaries
of the East Ham and West Ham CLPs (the two CLPs whose geographical area make up
Newham Borough). He asked them to email him a list of Constituency Labour Party (“CLP”)
affiliates and stated that:
“Affiliates that have been affiliated to the CLP for at least 60 days prior to the freeze date of 25
October 2016 are entitled to make one affirmative nomination even if that organisation has affiliated
to both CLPs.”
4 See para 17 below relating to the timetable and process

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19. The proper approach to affiliate voting was a cause of some concern and uncertainty during
the period before the Nomination Process was complete. In particular, it was unclear
whether each branch of an affiliate (that was affiliated to either CLP) was entitled to make a
nomination, or whether each affiliate was limited to one nomination irrespective of how many
branches were affiliated to the two CLPs.
20. On 19 November 2016 John Gray, Vice Chair of West Ham CLP and a member of the
UNISON NEC, emailed Mr Murphy and asked:
“I understand that 12 affiliates and forums are entitled to make nominations. As a member of
Newham LCF can you please advise me exactly who you (or the Regional Party) believe are entitled
to nominate.”
21. Despite sending chaser emails, he received no response. He complained on 30 November
2016 to Dan Simpson, the Regional Director for the Labour Party. Mr Simpson did not
respond either. The Nomination Process closed on 4 December 2016.
22. There has been no official confirmation of votes cast, despite requests from our clients.
However, the Claimants understand that 37 votes were cast and Sir Robin Wales was
nominated by 20 votes to 17. The votes were as follows:
1) All 20 Labour Party Branches voted: 11 selected an open process, 9 for reselection.
2) 3 CWU branches voted: 2 for reselection and 1 for an open process.
3) 2 Unite branches, 1 UNISON branch, the Newham Cooperative Party and West Ham
Women’s Forum voted for an open process.
4) 4 GMB branches and 1 USDAW, BECTU, Fabians and Christians on the Left branches
all voted for reselection.
23. Accordingly, it is clear that the different affiliates adopted very different approaches to their
voting rights. UNISON had six affiliated branches in the Borough, but only voted once. The
GMB voted four times. We understand that each affiliated organisation received one ballot
paper and that organisation then elected how to vote by reference to its own understanding
of the rules. Those divergent approaches were not identified, or the position clarified, at the
relevant time.
24. In addition to the misapplication of the rules in respect of affiliate voting (or alternatively the
misunderstanding of them), it has subsequently transpired that various of the voting affiliates

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were not entitled to do so. Clauses III and IV of Chapter 7 of the Labour Party Rule Book
2017 (“the Rule Book”) provide “Each affiliated organisation must: accept the programme,
principles and policy of the Party; agree to conform to the constitution, rules and standing
orders of the Party…” and that “all affiliation fees shall be paid not later than 31 December
of the relevant year.” Clause IX provides that affiliated organisations may take part in an
Annual General Meeting if their affiliation fees due to the CLP for the previous year ended
31 December have been paid a clear 35 days before the date of the meeting.
25. The Claimants understand that the Fabians had not paid their subscriptions fees for the
purposes of the 2016 Newham trigger ballot process and BECTU were also not up to date
with their payments. They also believe that there are concerns over the subscriptions of the
TSSA.
Previous correspondence
26. On 17 January 2017, a significant number of local party members (including the Claimants)
wrote a detailed letter to the NEC, raising a number of concerns about the Nomination
Process. The letter requested the NEC to hold an enquiry into the various flaws in the
process and not to endorse the selection until the enquiry had been concluded.
27. No substantive response was ever received. Indeed, it is not clear if the NEC ever engaged
with the concerns raised in that letter. One of the Claimants, Mr David Gilles, wrote an email
to the General Secretary of the NEC in advance of that meeting to request clarification of
the position on the concerns raised in the 17 January 2017 letter. On 30 January 2017, the
General Secretary responded and stated:
“The trigger ballot were [sic] raised very briefly at the NEC meeting on Tuesday and there was a
short discussion. However, the NEC did not discuss or agree to pausing or changing the result of
this process and the result stands.”
28. No further correspondence was received from the NEC or from the Labour Party.
III. Grounds of challenge
29. Each of the prospective grounds of claim below is currently formulated without the
opportunity to review the documents sought at paragraph 57 below. Our clients requested
disclosure from you in their letter of 17 January 2017, including internal correspondence, but
have had no response. Our clients reserve their right to supplement or amend the
prospective grounds of claim as set out below, in the light of the subsequent disclosure of
that material.

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Ground 1: The Procedural Rules were inconsistently applied
30. In breach of the contractual arrangements between the parties, the Procedural Rules were
applied inconsistently, in the course of the Newham trigger selection process. In particular:
1) Some affiliates were allowed to vote more than once, others only voted once each;
2) Mr Murphy (and/or other agents of the Labour Party) failed to ensure that the
Procedural Rules were applied in the same manner to the different affiliates;
3) The prospect of inconsistent application of the Procedural Rules was raised during the
trigger ballot process (see the email of Mr Gray to Mr Murphy of 19 November 2016);
and
4) Mr Murphy (and/or other agents of the Labour party) failed to respond to that email
and/or failed to take the necessary steps to ensure that the Procedural Rules were
consistently applied;
5) Following the end of the process, none of Mr Murphy, Mr Dawood, Mr Simpson, the
General Secretary of the Labour Party or the NEC itself have provided any explanation
of who was entitled to vote.
31. The Claimants will seek a declaration that the Labour Party (via the agency of Mr Murphy,
the NEC and other individuals as appropriate) breached its contractual obligations by failing
to ensure that the trigger ballot was conducted in accordance with the Procedural Rules.
32. For the avoidance of doubt, the Claimants do not need to show (on a but for basis) that the
inconsistent application of the rules would have resulted in a different result in the trigger
ballot procedure. Nonetheless, and for the sake of completeness, the Claimants’ position is
that the result would (or might) have been different if the Procedural Rules had been
consistently applied.
33. Also, for the avoidance of doubt, the Claimants do not consider that they need to satisfy the
Court as to the proper construction of the Procedural Rules in respect of affiliate voting, in
order to succeed with this ground of claim. The inconsistent application of the Procedural
Rules was a sufficient breach, in and of itself.

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Ground 2: The Procedural Rules were inconsistently explained
34. Further and alternatively, it is an implied term of the agreement between the parties that the
Labour party would take necessary and sufficient steps to ensure that the Procedural Rules
are consistently understood by the voting affiliates.
35. In breach of that implied term, the Labour Party (acting via the agency of Mr Murphy, the
NEC and other individuals as appropriate) failed to take any or sufficient steps to ensure that
the voting affiliates understood the Procedural Rules consistently. In particular Mr Murphy
(and/or other agents of the Labour party):
1) Failed to communicate the position in respect of affiliate voting with sufficient clarity;
2) Failed to respond appropriately when the possibility of inconsistent interpretations was
drawn to his attention;
3) Failed to take any or sufficient steps to clarify the position; and
4) Allowed different Trade Unions to exercise their rights under the Procedural Rules on
an inconsistent basis.
36. The Claimants will seek a declaration to that effect and repeat paragraphs 32 and 33 above.
Ground 3: The NEC failed to investigate
37. Further and alternatively, as set out above, the NEC has a contractual obligation to uphold
and enforce the constitution, rules and procedures of the Labour Party. It also has a broad
contractual power to investigate alleged breaches of the Party Rules.
38. The Claimants went to great lengths to detail the flaws in the Nomination Process to the
NEC. Those flaws were spelt out in the letter of 17 January 2017.
39. In breach of its obligation to uphold and enforce the Constitution, rules and procedures of
the Labour Party the NEC:
1) Failed to conduct any, or a sufficient, enquiry or investigation into the underlying facts
identified in the letter of 17 January 2017;
2) Failed to respond substantively to the letter of 17 January 2017;

9. 9
3) Failed to even consider the need for a full investigation, in the exercise of its
contractual powers; and
4) Failed to consider the matters raised in the letter of 17 January 2017 properly or at all:
the full extent of the consideration amounted to a “short discussion” which was dealt
with “very briefly”.
40. Those failures were particularly serious, in light of the prima facie case of inconsistent
application and/or understanding of the relevant rules raised in the letter of 17 January 2017.
41. The Claimants will seek a declaration to that effect and repeats paragraphs 32 and 33 above.
Ground 4: The NEC unlawfully endorsed the nomination, in the face of strong prima facie
evidence that it was flawed
42. Further and alternatively, in breach of its contractual obligations, the NEC endorsed the
nomination of Sir Robin Wales without conducting a proper, or any, investigation of the
underlying flaws of the trigger ballot procedure. In particular, the NEC:
1) Affirmed the nomination following a very brief discussion on 4 February 2017;
2) Failed to treat the matters raised in the letter of 17 January 2017 seriously, or
sufficiently seriously; and
3) Failed to uphold the constitution, rules and procedures of the Labour Party.
43. To the extent that such a term needs to be implied, it was an implied term of the agreement
between the parties, that the NEC would not endorse the nomination of a Labour candidate
for a directly elected mayoral position where there was prima facie evidence that the
nomination had been procured in breach of the constitution, rules and procedures of the
Labour Party.
44. The Claimants will seek a declaration to that effect and repeats paragraphs 32 and 33 above.
Ground 5: The Procedural Rules were wrongly applied
45. Further and alternatively, the Labour Party (via the agency of Mr Murphy and/or other
individuals) wrongly applied the Procedural Rules governing the trigger ballot selection
procedure in Newham, on two bases.

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46. Firstly, in breach of Rule 3.1 of the Procedural Rules, some affiliated organisations were
allowed to cast one vote for each affiliated branch of an affiliated organisation: in the case
of the GMB four votes were cast.
47. Rule 3.1 provides:
“The affiliated organisations entitled to make an affirmative nomination are those affiliated to any
CLP with a geographical interest in the electoral area (London borough) as at 31 December of the
previous year. Each affiliated organisation is entitled to make one affirmative nomination only even
if it is affiliated to more than one CLP with a geographical interest in the electoral area (London
Borough).”
48. Rule 3.1 is clear that each affiliated organisation is only entitled to one vote. The affiliation,
which is relevant for these purposes, is an affiliation by that particular organisation to a CLP
with a geographical interest in the electoral area. Whether or not multiple branches of the
organisations are affiliated to the respective CLPs is irrelevant. The rule remains ‘one
affiliate, one vote’. Were the position otherwise, the provisions within Rule 3.1 that only allow
affiliated organisations “one vote only”, whether or not they are affiliated to more than one
CLP, would not be workable.
49. A construction of Rule 3.1 which allows affiliated organisations with multiple branches
affiliated to cast a vote by or for each affiliated branch contradicts the substance and the
spirit of the Procedural Rules. In breach of Rule 3.1 Mr Murphy (and/or other agents of the
Labour party):
1) Allowed the GMB to cast four votes in the nomination process;
2) Allowed the CWU to cast three votes in the nomination process; and
3) Allowed Unite to cast two votes in the nomination process.
50. In any event, the Claimants seek disclosure of the ballot papers of the various voting
affiliates, in order to confirm that they were returned by the individual branch affiliates in
question (see below).
51. Secondly, the Claimants have grounds to suspect that, in breach of Clauses III and IV of
Chapter 7 of the Rule Book, affiliated organisations that had not paid their affiliation fees
were entitled to vote in the trigger ballot selection process.
52. Clauses III and IV of Chapter 7 provide:

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“Each affiliated organisation must: accept the programme, principles and policy of the Party; agree
to conform to the constitution, rules and standing orders of the Party…”
…
“all affiliation fees shall be paid not later than 31 December of the relevant year.”
53. When read in conjunction with Rule 3.1 of the procedural rules, it is clear that an affiliated
organisation, that has not paid its affiliation fees, is not an affiliate, for the purposes of
participation in the affirmative nomination process. In particular:
1) Clause IX of Chapter 7 which provides that affiliated organisations may take part in an
Annual General Meeting if their affiliation fees due to the CLP for the previous year
ended 31 December have been paid a clear 35 days before the date of the meeting;
and
2) The letter of the Procedures Secretary Mr Murphy (dated 28 October) stated that
“affiliated organisations eligible to make an affirmative nomination are those that have
been affiliated… at least 60 days prior to the freeze date.”
54. The Claimants understand that the Newham Fabian Society have not paid their
subscriptions since 2010 and that BECTU were also behind with their payments. In breach
of the Rule Book, Mr Murphy (and/or other agents of the Labour Party):
1) Failed to take any or sufficient steps to confirm that the voting affiliates had paid their
affiliation fees;
2) Failed to take any or sufficient steps to confirm that the voting affiliates were “affiliates”
in the sense that they were entitled to participate in the vote; and
3) Allowed some organisations to vote in the trigger ballot that were not entitled to do so.
55. The Claimants will seek declarations to that effect. The Claimants repeat paragraph 32
above: they do not need to show that the result of the trigger ballot would have been different,
but they consider that they would meet that threshold in any event.
56. The Claimants accept that they would need to satisfy the Court as to the proper construction
of the Procedural Rules and/or Rule Book in order to succeed on this Ground of Claim.
IV. Disclosure and preservation of documents
57. The Claimants seek pre-action disclosure of:

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1) Internal memoranda, notes, emails, minutes, messages, communications and other
documents recording the discussion of the NEC held on 24 January 2017;
2) Internal memoranda, notes, emails, minutes, messages, communications and
correspondence of Ian McNicol, and other members of the NEC / Labour Party staff
relating to the trigger ballot nomination process in Newham between 25 October 2016
and 4 December 2016;
3) The correspondence (including but not limited to emails, letters, WhatsApp messages
and text messages) of Mr Murphy, in particular between 15 October 2016 and 15
December 2016, relating to the trigger ballot process:
1) To the Secretaries (or other relevant officers) of the relevant CLPs;
2) To the Secretaries (or other relevant officers) of the relevant party branches;
3) To the Secretaries (or other relevant officers) of the affiliated organisations that
voted in the trigger ballot process;
4) To the NEC of the Labour Party (or any other representative thereof);
5) To Dan Simpson (the Regional Director of the Labour Party) and other officers
of the London Regional Labour Party; and
6) To the Labour Campaign Forum in Newham.
4) The correspondence (including but not limited to emails, letters, WhatsApp messages
and text messages) of the various secretaries of the CLPs and branches of the Labour
Party in Newham between 25 October 2016 and 4 December 2016 relating to the
trigger ballot process:
1) To the Secretaries (or other relevant officers or members) of the affiliated
organisations that voted in the trigger ballot process;
2) To the NEC of the Labour Party (or any other representative thereof);
3) To Dan Simpson (the Regional Director of the Labour Party).
5) The nomination papers returned in association with the selection process; and

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6) Current lists of the organisations affiliated to the relevant CLPs and branches of the
Labour Party in Newham including records of the dates on which their affiliation fees
were paid in the last two years and dates and records of their affiliating, if they affiliated
in the last two years.
58. This information will assist us in assessing the strength of the claim and refining it. If you
decline to provide that information, please explain why in respect of each category of
information sought.
59. In any event, please confirm that you will immediately take steps to ensure that all the
categories of document referred to in this letter will immediately be searched for, identified
and secured as per CPR PD 31B(7). You should thereafter preserve all documents –
including electronic documents – relating to this claim.
V. Steps we expect you to take
60. In light of the material set out in the letter of 17 January, and this pre-action letter, we invite
you to withdrawn the NEC’s endorsement of Sir Robin Wales immediately and either:
1) Order a new and open selection process; or
2) Open an investigation into the trigger ballot selection procedure as soon as
practicable. The Claimants recognise that it may not be possible to conduct that
investigation until after the General Election on 8 June 2017;
61. As a further alternative, the Claimants invite you to
1) Declare the previous trigger ballot procedure invalid; and
2) Schedule a fresh trigger ballot nomination procedure in Newham.
VI. Proposed reply date
62. Please provide a response to the matters raised in this letter within 14 days (in the light of
the comparative urgency of the matter), by no later than 29 May 2017. We recognise that
this is shorter than the 21 days provided by the Pre Action Protocol. However, given the
urgency and the seriousness of the matters in issue, we invite you to respond more quickly.

14. 14
63. The Claimants are conscious that the upcoming General Election will be the priority for the
Party at present. The Claimants therefore suggest that you either withdrawn the NEC’s
endorsement of Sir Robin Wales immediately and / or declare the previous trigger ballot
procedure invalid as an immediate step. In that event, our clients are prepared to stay the
consequent steps pending the outcome of the General Election. Alternatively, our Clients
ask that you agree to move straight to an open re-selection process after the General
Election in order to save time and costs.
64. Should you fail to agree to take the steps taken above, our clients will seek your agreement
to an expedited trial of this matter before the High Court within two months of proceedings
being issued. The need for expedition arises from the forthcoming council selection process
in Newham and the need to re-run the trigger ballot and, if applicable, open selection
process.
65. Please confirm your position as to an expedited hearing in your letter of response.
Should you have any queries related to the matters raised in this letter, please do not hesitate to
contact Mr Ravi Naik of our offices.
Yours faithfully
IRVINE THANVI NATAS SOLICITORS
cc. Ian McNicol, General Secretary of the Labour Party, Southside, 105 Victoria Street,
London, SW1E 6QT