The requirements of procedural fairness in the context of club disciplinary proceedings was reviewed in Barrie v. Royal Colwood Golf Club, 2001 BCSC 1181 (CanLII) at paragraphs 55-71. Those requirements are less rigorous in a club than in other contexts for reasons explained in the authorities cited in those paragraphs. They amount to “fair play”, that is, reasonable notice and an opportunity to be heard by decision-makers open to persuasion.
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