strong enough to engage in serious collective bargaining”. 42 Other labour legislation enacted in 1980 and 1981, and then incorporated into the Labour Relations Act, 1985, equally included governmental involvement in labour relations. 43 For example, the Employment (Conditions of Service) Regulations, 1981 required prior ministerial approval for retrenchments. 44 The granting of such powers to the Minister of Labour restricted the “employers’ hitherto unlimited powers to hire and fire”. 45 Black workers were now considered to be “employees” like their white colleagues. 46 96. The Labour Relations Act, 1985 also created a number of labour institutions, including workers committees, works committees and trade unions at the enterprise or industry level, and national tripartite employment councils, employment boards, the wages and salaries advisory board, the retrenchment committee, the labour relations board and the labour relations tribunal. During this time, there was a trend towards the merging of smaller trade unions into larger ones. 97. From the mid-1980s, the close link between the Government and the ZCTU came under pressure as the country experienced an economic downturn and the union challenged the socio-economic policies of the Government. The ZCTU supported a protest by students in 1989, during which Mr Morgan Tsvangirai, its Secretary General since 1988, was arrested. 98. In 1991, with the introduction of the Economic Structural Adjustment Programme (ESAP), and the deregulatory Labour Relations Amendment Act, 1992, strains in the relationship between the Government and the ZCTU became more marked. The Government began to use the Law and Order Maintenance Act in relation to protests against labour law reforms in 1992. 47 99. Industrial unrest increased and took the form of strikes in a number of sectors. 48 In 1994, there were strikes in the post and telecommunications, health, banking, construction and insurance sectors. 49 In 1995, the ZCTU launched a publication arguing against the Government’s structural reform programme, 50 which “led to government charges of union involvement in 42 Sachikonye, op. cit., p. 111. 43 The Employment Act, 1980, the Employment (Conditions of Service) Regulations, 1981 and the Emergency Powers (Termination of Employment) Regulations, 1982. 44 See Sachikonye, op. cit., p. 111. 45 Sachikonye, op. cit., p. 111. 46 Dansereau (2000), op. cit., p. 234. 47 Sachikonye, op. cit., p. 124. 48 Sachikonye, op. cit., pp. 121���2. 49 Dansereau, op. cit., pp. 110–112. 50 ZCTU, 1995, Beyond the economic structural adjustment programme: Framework for a longterm development strategy in Zimbabwe (ZCTU, Harare). 36 Meetings-2009-Zimbabwe C of I-2009-12-0035-3-En.doc/v3