Tonga National Rugby League v Rugby League International Federation

The Tonga National Rugby League, represented by its players, sought an interlocutory injunction against the Rugby League International Federation to challenge the Federation's rules that prevented the players from representing the Tongan national side. The High Court was tasked with determining whether these rules constituted an unreasonable restraint of trade and if the balance of convenience favoured granting the injunction.

The primary legal issue was whether the Federation's rules, which prevented the players from participating in international competition, constituted an unreasonable restraint of trade. The court considered the players' arguments that they were engaged in trade by being available to play for Tonga, even if not currently playing for reward, and the Federation's contention that the rules were necessary to maintain the credibility of international competition. The court also weighed the relative strength of the parties' prima facie cases and the potential impact of the injunction on both the players and the Federation.

The court found that the Federation's rules were not an unreasonable restraint of trade as they appeared to be no wider than necessary to protect the interest in the credibility of international competition. The rules were more liberal than those of other similar bodies, and the players had not demonstrated a sufficiently strong prima facie case. The balance of convenience did not favour the players, especially given the players' weak case, and granting the injunction would effectively determine the claim for final relief. Consequently, the court refused the injunction.

The court's final orders were that the interlocutory injunction sought by the Tonga National Rugby League was refused.