McCarthy v Penrikyber Navigation Colliery Co Ltd Lord St Aldwyn’s Award, made under the Coal Mines (Minimum Wage) Act 1912, provides that the following questions shall be referred to the trade tribunal: (a) as to whether a workman is one to whom the minimum rate applies; (b) whether the workman has complied with the rules of the award; and (c) whether such non-compliance has worked a forfeiture of his right to the minimum rate.