Therefore, in order to practically protect the three labor rights, a plan to include industrial actions regarding rights disputes, collective labor-management relations, and layoffs within the scope of collective actions stipulated by the Trade Union Act, a plan to delete the last resort requirement for collective actions, a plan to amend Article 3 of the Trade Union Act so that the scope of immunity is not limited to “legitimate” collective bargaining and action, and a plan to make exceptions to illegal acts, such as violence and destruction, for being subjected to compensation for damages, rather than making labor unions activities subjected to civil immunity, regardless of justification are proposed. On the other hand, those who oppose the revision of the Trade Union Act claim that the Yellow Envelope Act excessively violates the employer’s property rights, which is a fundamental right under the Constitution, by exempting even illegal acts, not legitimate industrial actions. In many cases, collective actions in Korea include a use of force, such as destruction of business or taking over the facilities, and claiming compensation for the damages from the illegal actors is not abusing the rights and is a basic principle of legal order.526) In particular, based on the Ministry of Employment and Labor’s survey ‘results of damage compensation lawsuits and provisional foreclosure survey and overseas cases’ (Oct. 2022), most of the cases cited and decided by the courts in actual damage claims lawsuits had issues with the means of the collective action, such as use of force during the process. Therefore, it is asserted that even under the current legal system, the additional restrictions on damages are unnecessary as the courts limits the amount of damages and the person responsible only when there is a causal relationship between the tort and damages. In addition, it is presented that there was a case in France, which held a law with a similar purpose to the Yellow Envelope Act unconstitutional, and that there is no foreign legislative precedent that provides immunity even to illegal acts.527) 525) PSPD, “Misunderstanding and the Truth about ‘Yellow Envelope Law’,” Nov. 3, 2022 526) Legal Times, [Your Opinion on this Law] Controversy over ‘Yellow Envelope Law,’ Oct. 26, 2022. 527) Labor Law, Business associations “Yellow Envelope Law violates the right to property of the employers and harms market economy,” Sep. 14, 2022. 217