Boys Markets, Inc. v. Retail Clerks Union Local 770, 398 U.S. 235, 90 S.Ct. 1583, 26 L.Ed.2d 199 (1970), established that the federal courts could, in certain circumstances, enjoin strikes by unions over arbitrable issues. Strikes were the very tactic that arbitration was to obviate and a no-strike obligation, express or implied, was the union's quid pro quo for the employer's undertaking to submit contract disputes to binding arbitration. Unless an employer could have strikes over arbitrable issues enjoined, arbitration as the method for resolving industrial disputes would be severely undermined. Injunction in these circumstances thus enforced a critical underpinning of the arbitral process.