Compendium of Standards, Good Practices and Recommendations may be associated with other trade unions through a federation. Despite the apparent risks of external influence and industrial militancy, the experience of such arrangements in the Netherlands has been one of self-restraint. Strike action, for example, has never been taken. Moreover, the potential advantages of such a collaboration should be considered. The human rights compatibility of some of these arrangements is now in doubt, following a significant ruling in 2018 by the Council of Europe’s European Committee of Social Rights. The case was brought to the Committee by EUROMIL, which alleged that Ireland was in violation of Articles 5 and 6 of the Revised European Social Charter, on the grounds that the defence force representative associations did not possess proper trade union rights. The Committee concluded that Article 5 and Article 6(2) of the ESC had been violated but that there was no violation of Article 6(4) of the Charter. The decision is discussed in detail in Box 7.9. Box 7.9: Military associations and the European Social Charter268 Ireland’s defence legislation had established two associations to represent officers, among other ranks, and perform limited consultation and conciliation roles. The associations were independent but could not associate with or be affiliated to any trade union or any other body without the consent of the Minister of Defence. They were not permitted to “sponsor or resort to any form of public agitation as a means of furthering claims or for any other purpose”. Individual members of the Defence Force were prevented from joining trade unions and from engaging in strike action. One of the associations, the Permanent Defence Forces Other Ranks Representative Association (PDFORRA), sought the consent of the Minister of Defence to become affiliated to the Irish Congress of Trade Unions (ICTU) but was refused. This prevented PDFORRA from attending the national negotiations that ICTU conducts on salaries in the public service sector. As a non-governmental organization entitled to submit complaints to the European Committee of Social Rights, EUROMIL was able to lodge a complaint against Ireland, in support of PDFORRA (a EUROMIL member organization). Inability to affiliate to trade union associations The Committee found that, while Article 5 allows states to impose restrictions on the right of service personnel to organize, and granted a wide margin of appreciation, these restrictions could not go so far as to entirely suppress the right to organize, such as by instituting a blanket prohibition of trade unions and of professional associations’ affiliation to national federations/confederations. The Committee rejected the Irish government’s contention that the total prohibition was necessary and found that a complete ban on affiliation was neither necessary nor proportionate (see paragraphs 55-56). 268 European Committee of Social Rights, op. cit., note 256; and “The European Social Charter”, The Council of Europe, https://www.coe.int/en/web/european-social-charter. 123