Courts may intervene in voluntary association disciplinary proceedings not only on contractual grounds but also on broad principles of justice, particularly where a member's livelihood depends on membership. A charge of misconduct based on false statements must identify the mental element (dishonesty, recklessness, negligence) and a disciplinary tribunal must make findings as to that element; failure to do so renders the finding materially ambiguous and void. The rule against duplicity applies as a guideline of elementary fairness in voluntary association disciplinary proceedings.
The full text is available to signed-in members, including the 18 later cases that cite this judgment.