The Supreme Court confirmed that under s 182 of the Associations Incorporation Act 2015 (WA) (in its pre-August 2025 form), a person who disputes the validity of their expulsion from an incorporated association has standing to apply to the State Administrative Tribunal as a 'member', because if the expulsion was invalid they remain a member; the question of standing is bound up with the substantive question of whether the rules were complied with. The Court also held that the 2025 amendments adding standing for 'former members' did not retrospectively confirm that expelled members previously lacked standing, and that the Tribunal's power under s 182(3) extends to making declarations as to membership status and is not limited to a narrow supervisory or procedural inquiry. On the Pabla Appeal, the Court held that the Tribunal did not exceed its jurisdiction or deny procedural fairness by determining the validity of an expulsion that occurred after the application was filed, where the issue was squarely raised and addressed by both parties during the proceedings.
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