A store closed before entry (or a simple closed store) is a form of union security agreement under which the employer undertakes to recruit only union members and workers must remain members of the union at all times to remain employed. This is different from a closed company after entry (Us: Union Shop) which is an agreement that requires all workers to join the union if they are not already members.  In a union activity, the union must accept as a member any person hired by the employer.  The European Court of Human Rights has stated that Article 11 of the European Convention on Human Rights provides, in Seensen and Rasmussen/Denmark (2006), for “a negative right of association or, in other words, a right of non-membership of an association”. As a result, closed transactions are illegal under section 11 of the agreement. The famous English damages case Rookes v Barnard concerned a store agreement.  Dunn and Gennard found 111 layoffs in the United Kingdom when a closed store was introduced, “While supporters of the closed store can argue that it is estimated that at least 325 layoffs are a relatively small number compared to the total population covered by closed stores, critics would consider this figure to be substantial and argue that a layoff is one too many.” :126 With regard to the store closed before entry, they stated: “Its raison d`être is to exclude people from jobs by denying them union membership.” :132 The status of closed businesses varies from province to province within Canada. The Supreme Court held that the second part of the Charter of Rights and Freedoms guarantees both the freedom of associates and the freedom not to participate, but workers in a workplace largely dominated by a union have benefited from union policy and should therefore pay trade union rights, regardless of affiliation status. However, the objectors of the war had the opportunity to pay the sum to a registered charity. In some cases, unions have a monopoly on a certain industry and companies in that sector. If that is the case, all businesses in an area must hire union workers, and they call it a “closed business.” All forms of closed business in the Commonwealth are illegal under the 1996 Labour Relations Act.