Clubs

In the course of a dispute about the management of a working men’s club, the claimant sought orders, including as to the validity of a meeting electing club officers. The judge held the meeting was valid, despite failure to comply with the club rules. The claimant appealed. Allowing the appeal, the Court of Appeal held that an election by acclaim or a show of hands, when the rules required a ballot, was not a failure of form rather than substance. Adequate notice of the business to be transacted at the meeting had not been given and the irregularities had not been mere matters of form. Accordingly, the president and the treasurer had not been validly elected. With respect to the committee members, the absence of nomination sheets for the three weeks preceding the meeting meant that the names of the candidates had not been publicised in advance of the meeting and there had been no opportunity to propose alternative candidates. That