The first recorded industrial action in Australia was in 1791 – convicts demanded daily rations instead of weekly. Howard’s attempts to make union activism illegal are not new – they hark back many years. In 1828 the Masters and Servants Act of NSW provided that ... "servants could be imprisoned and have their wages forfeited for refusal to work or for destruction of property, and that Masters found guilty of ill-usage should be liable to pay damages up to 6 months wages".