Carmody v Roseville Golf Club Ltd

[2026] NSWSC 45

Supreme Court of NSW

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Interrogate

Catchwords

1. Associations and Clubs
2. › Domestic and private tribunals
3. › Disciplinary proceedings
4. › Expulsion of member
5. › Procedural fairness
6. › Whether Appeals Committee required to give reasons
7. › Whether member entitled to know identity of complainant or witnesses
8. › Whether charge adequately particularised
1. Associations and Clubs
2. › Domestic and private tribunals
3. › Disciplinary proceedings
4. › Wednesbury unreasonableness
5. › Whether finding of guilt and penalty of expulsion so unreasonable that no reasonable decision-maker could have reached them
1. Associations and Clubs
2. › Domestic and private tribunals
3. › Disciplinary proceedings
4. › Bias
5. › Whether actual or apprehended bias established
6. › Whether apprehended bias sufficient to vitiate decision of domestic tribunal

Quick Take

A club's Appeals Committee has no obligation to give reasons for its decision where the constitution requires only notification of the 'outcome', and the absence of an express exemption from giving reasons (unlike for the initial disciplinary committee) does not give rise to an implied obligation to provide reasons.