[brief] *Battaglia v. United Parcel Serv., Inc.*, 214 N.J. 518, 547 (2013)  In this case Plaintiff easily satisfies the elements of retaliation under the NJLAD.  The Association additionally asserts claims that the promotional policy exists as an arbitrary and capricious exercise of Defendant’s municipal authority.  A Plaintiff may always challenge a policy adopted by a municipality that violates the law.  In this case the New Jersey Law Against Discrimination grants a private cause of action to any “person”, including labor organizations, who challenge policies or the application of such policies as violative of the New Jersey Law Against Discrimination.  In this case the Association has standing to bring its claims on behalf of all of its impacted members. \(^3\)  Declaratory Judgement actions are the appropriate vehicle to challenge municipal policy.  Municipalities are granted the general power to provide for the employment necessary for the efficient conduct of their affairs.  See N.J.S.A. 40:48-1(3) and 2.  It is the long established legal rule that all powers delegated to municipalities must be exercised reasonably and not arbitrarily and they must not contradict statutes adopted by the State.  Kennedy v. City of Newark, 29 N.J.  178, 184-185 (1959).  Under the facts of this case the City’s promotional policy is a direct violation of the NJLAD.  The City relied upon a proscribed discriminatory factor in making its decision to take the adverse employment action against Firefighters - ie. rendering them ineligible for promotion.  Not only is the City Policy violative of the NJLAD it is also an arbitrary exercise of municipal agency.  The promotional policy is an obviously unreasonable and arbitrary exercise of delegated power, and hence illegal.  See, Ebler v. Newark, 54 N.J. 487, 490-91 (1969).  (Policy which denied sick leave benefits to Jewish police --- \(^3\)  The importance of representative standing as an efficient procedural vehicle for addressing the common rights of association members is well-recognized in New Jersey.  See N.J. Citizen Action v. Riviera Motel Corp., 296 N.J. Super. 402, 415 (App. Div. 1997) (stating that "New Jersey courts take a broad and liberal approach to standing")  The [...] has a strong interest in vindicating the rights of its members.  officers declared void)  “It is the long established rule . . . that all powers delegated to municipalities must be exercised reasonably and not arbitrarily. ”  We also note that rendering persons ineligible for promotion simply because they avail themselves of medical leave provided under Civil Service law violates the laws of New Jersey.  See, N.J.S.A. 11A:6-15.  “A leave of absence shall not disqualify an applicant for a promotional examination. ”; N.J.A.C. § 4A:10-1.1(c)  “No person or appointing authority shall obstruct a person's lawful opportunity to participate in the selection and appointment process....”; N.J.A.C. 4A:10-1.1  “No person or appointing authority shall violate the provisions of Title 11A, New Jersey Statutes, or Title 4A”  In this case the City’s actions are arbitrary where they deny promotional eligibility to disabled persons or persons perceived to be disabled.  This is an abuse of discretion.  Where such policies are arbitrary and violate the NJLAD, and other New Jersey Laws, directly, and facially, they are subject to nullification as a matter of law.