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Trade unions were not criminal conspiracies in Canadian law prior to the passage of the Trade Unions Act. In a series of trials between 1854 and 1872 the Toronto criminal courts consistently failed to convict workers on evidence that would have warranted conviction had combinations to raise wages or lessen hours been considered to be criminal conspiracies. Analysis of the English case-law reveals a lack of judicial consensus that such combinations were criminal conspiracies, and in any event all such statements of law were merely obiter dicta. While such trade union purposes as raising wages could serve as evidence of combination, there was no criminal conspiracy in the absence of specific crimes.