Educational leadership/management scholars have undertaken work which documents the difficulties particular headteachers face when implementing policy. Some have suggested that headteachers mediate policy, ensuring the best possible outcomes for their schools, but there is also critique of this argument and a counter-suggestion that heads ought to resist the imposts of conservative, marketised policies which produce and reproduce educational inequities. In this article I consider this position, and argue that if the field is to take up the question of resistance then it will need to extend its theoretical resources, interrogate and test out the limits of the proposition through empirical example, consider instances where resistance appears to occur, and move beyond a focus on individual headteachers to take seriously their collective professional organisations. In making this argument, I generate some suggestions for future research. (Contains 1 figure and 57 footnotes.)