Salvation Army v Canterbury Hotel Employees Union - [1985] 2 NZLR 366

Industrial law — Awards — Exclusion from awards — Salvation Army ran rest homes for the elderly — Homes were a charitable operation but patients were charged such fees as they could afford — Whether the staff employed in the rest homes were employed for the direct or indirect "pecuniary gain" of the employer — Whether the Salvation Army was exempt from complying with the provisions of the Rest Homes' Employees Award — Industrial Relations Act 1973, s 213.