V1l of 1978 KAYNE v. BANKS & ORS. ' N.S.W. 15 of 1978 ! CROYSTON v. A.B.C. STAFF ASSOCIATION CATCHWORDS Industrial law - interpretation of the rules of an organization ~ Validity of alterations to the rules of an organization ~- Necessity to comply with provisions of rule-making power ' - Effect of certificate of Industrial Registrar under s.139(4) Conciliation and Arbitration Act, 1904 - validation of invalid aaa wt alterations Australian Broadcasting Act, 1942 r Conciliation and Arbitration Act, 1904, ss. 132, 133, 133AA, 139(4) | and s.i7ic Conciliation and Arbitration Regulations, Reg. 115 IN THE FEDERAL COURT OF AUSTRALIA INDUSTRIAL DIVISION ' V No. 11 of 1978 BETWEEN: SIVAN KAYNE Claimant and JOHN FRANCIS BANKS, RONALD JOSEPH MINOGUE, : ~ROBERT JOHN CARE-WICKHAM, WILLIAM GIBBS, MICHAEL COSBY, FRANCIS LEE, B. FULLER, ADRIAN BRENNAN, ROGER CATCHPOOLE, DAVID HAWKES, DAVID STUART-WRIGHT, ROSEMARY DARRAGH, JOHN QUINN, ' JOHN GARTON, EDWARD REYNOLDS, ELIZABETH FELL AND ' ~ THOMAS MOLOMBY Respondents ' if AND i BETWEEN: N No. 15 of 1978 a JOHN FREDERICK CROYSTON Claimant and » THE AUSTRALIAN BROADCASTING COMMISSION STAFF ASSOCIATION AND IVAN KAYNE Respondents SWEENEY J. EVATT J. REASONS FOR JUDGMENT 6 November 1978 NORTHROP J. These applications are further illustrations of the fact that many officials of organizations, when applying the rules of their organization, do not pay attention to the particular rules conferring the power to alter the rules of the organization. Time and time again, in making an alteration to rules, the relevant procedures laid down by the rules of an organization are not followed but nevertheless the purported alteration has appeared to have come into effect upon the Registrar giving his certificate under s.139(4), Conciliation and Arbitration Act 1904 as amended (the Act). The failure to follow the relevant procedures has resulted in latent defects in the validity of the rules alteration and has led to uncertainty among and misunderstanding between members of the organization. In many cases, legal proceedings have resulted, often many years later, to test the validity of the purported rules alteration and of actions taken in reliance upon those rules. On 21st October, 1977, s,139(4) of the Act was amended by s.16, Commonwealth Conciliation and Arbitration Amendment Act (No. 3) 1977 and, since then, in addition to the other matters specified in that sub-section, the Registrar has been required to certify that in his opinion the alteration "has been made in accordance with the relevant procedures laid down by the rules of the organization", This statutory requirement should be of great assistance in ensuring that an alteration to the rules of an organization does not come into effect unless the relevant procedures have been followed. The Australian Broadcasting Commission Staff Association (the Association) is an organization under the Act. The members of the Association are persons employed by the Australian Broadcasting Commission (the A.B.C.) whose general conditions of employment are prescribed by the Australian Broadcasting Act 1942, with the exception of senior officers, There are six branches of the Association, one in each of the States, and the general management of the affairs and finances of each branch is vested in a branch committee, The members in each branch elect the members of their respective branch committees. The Federal Conference is the supreme governing body of the Association and meets at least once in every 18 months, Rule 11, and consists of the Federal President, two Federal Vice-Presidents, Federal Secretary and Federal Treasurer, who together constitute the federal officers, and one delegate from each branch, Rule 12. In addition to the ordinary Federal Conference, special meetings of Federal Conference may be convened, Rule 12. At meetings of Federal Conference, each delegate has one vote for every 50 financial members, or part thereof, 1n the branch which he represents while the federal officers, other than the Federal President, have the power to move and second motions and amendments but have no vote and the Federal President has a casting vote only, Rule 19. Branch committees have the power to instruct their delegates how to vote, Rule 20. A branch delegate to Federal Conference, provided he remains a member of the branch committee, holds office from the date on which he 1s declared elected until the date on which the branch delegate to the following Conference (not being a special Conference) is declared elected, Rule 20, Rule 14 lists the general powers of Federal Conference and the following paragraphs of Rule 14 are set out: of 3505 Serene rng re re TA NR I NS ee ere: "14, A meeting of Pederal Conference shall have power - (b) to make, alter, amend or rescind in the Manner provided; eereneesesn (i) to delegate any of its powers to any two or more members or to any Federal Body of the Association," Rule 14(b) is to be read as if the word "rules" appeared immediately after the word "rescind". Rule 17 empowers Federal Council, when Federal Conference is not 1n session, to submit any matter to branch committees for decision by vote and any decision obtained shall be binding as if such decision had been obtained by a vote at a regularly constituted meeting of Federal Conference, Rule 56 provides for the alteration of the rules of the Association and is as follows: " REPEAL, ALTERATIONS OF AND ADDITION TO RULES 56. These Rules may be repealed, altered or added to from time to time - (a) By a resolution of the Federal Conference. Provided that any Branch Committee proposing to move any repeal or alteration of or amendment to the Rules shall notify the Pederal Secretary in writing thereof, and of the terms of the proposed repeal, alteration or addition six weeks at least before the day fixed for the meeting of the Federal Conference, at which it is proposed to move such motion, (b) By a plebiscite of the members of the Association provided that in or prior to the taking of which notice shall have been given to the members of the nature of the proposed repeal, alteration or addition. (c) The accidental omission to give notice to or the non-receipt of the notice by any Branch Committee or in the case of a plebiscite or ballot, the accidental omission to give notice to or the non-receipt of the notice by any member shail not invalidate any repeal, alteration or addition to the Rules so made." ef 4aves The rules of the Association in force in November 1973 are hereinafter called "the o1d rules", Under the old rules, the federal officers were elected by the Federal Conference, Rules 15 and 22, the delegates to Federal Conference were elected by and from the branch committees, Rule 20, and the delegates to Federal Council were elected by the branch committees, Rules 24 and 36A, Rules 36A and 37 made provision for the appointment of returning officers to conduct elections while Rules 14 and 39 made provision ' for the dismissal of elected officers of the Association. Section 52 of the Conciliation and Arbitration Act 1973 amended s,133, Conciliation and Arbitration Act 1904-1972. The amendment came into operation on 13th November, 1973. Under s.133, as amended, the rules of organizations had to make provision for the election of the holder of each office within the organization at an election at which all financial members of the organization or branch, as the case may be, were eligible to vote, s.133(1) (a), the conduct of such elections by a returning officer not being the holder of any other office in and not being an employee of the organization or of a branch and for other specified matters, s.133(1) (b),(c),(d) and (e) and for restrictions on the dismissal ; from office of persons elected to office, s.133({1) (f). The amended ; s.133 contained certain saving provisions and allowed organizations ' a specified period of time within which to alter their rules in order to make them comply with s.133 as amended. The Association held a special Federal Conference on 30th April, lst, 2nd and 3rd May, 1974, The Federal Conference was held at a time of great industrial disputation between the Association and the A.B,C, as a result of which many officers of the Association were engaged in proceedings before the Public Service Arbitrator and the sessions of the Conference were thereby disrupted. To make matters worse, one of the recording devices used to record the proceedings at the Conference was defective and failed to record properly, Following the conclusion of the Conference, the then Federal President, a full-time paid officer of the Association, wrote to all members of Conference referring to the confusion of the records and seeking corrections to the draft resolutions passed, lost, withdrawn or lapsed in order to ensure a proper record of the proceedings of the Conference. At the hearing [Daas ] ul of the applications before this Court, much time was spent on examining and cross-examining witnesses who were present at the Conference as to what occurred at the Conference, but it is not necessary to consider that evidence in any detail, The necessity to alter the rules of the Association following the 1973 amendments to the Conciliation and Arbitration Act was referred to in the ° background papers prepared for the Conference and distributed prior to the Conference and in the Federal President's speech opening the Conference, It is clear that no alterations to the rules had been 1 prepared prior to the Conference and that no draft alterations were placed before the Conference. It is clear that no resolution of the Federal Conference altering the rules of the Association was mage at the Conference. The formal record of the Conference makes no specific reference to the alteration of the rules of the - Association. Some witnesses claim that a resolution was passed authorising either the federal president or the "Federal Office" to make the necessary alterations, Such a resolution, even 1f passed by the Conference, was not, for reasons to be given, an alteration of the rules of the Association made in the manner provided, Rule 14 (b), nor in accordance with the relevant procedures laid down by Rule 56 of the rules of the Association. There is no suggestion that a plebiscite of the members of the Association had been taken in relation to the alterations to the rules. Following the 1974 special Federal Conference, the then Federal President, who at present is overseas, caused a number of alterations to be made to the rules of the Association. The alterations were intended to bring the rules into conformity with the 1973 amendments to s,133 of the Conciliation and Arbitration Act. The alterations involved the insertion of a new Rule 9A and alterations to Rules 14, 15, 20, 22, 24, 25, 36A, 37 and 39 of the old rules, The Federal President lodged with the Registrar the alterations to the rules of the Association for the purpose of obtaining a certificate under s.139 of the Act. Initially, the Registrar refused to give his certificate with respect to all the alterations but eventually, after discussion between the Registrar and the Federal President, the alterations were drafted in a form acceptable to the Registrar to enable him to give his certificate. In the meantime, the Conciliation and Arbitration Amendment Act 1976 (Act No. 64 of 1976) received the Royal Assent on 9th June, 1976. «/Gene Section 13 of that Act inserted a new s.133AA into the Conciliation and Arbitration Act. Section 133AA provides that elections for certain specified offices within organizations shall be by secret postal ballot, Section 133AA did not come into operation until 9th August, 1976. Following the enactment of Act No, 64 of 1976, the Federal President, in purported reliance on Rule 17 of the rules of the Association, submitted by telegram a matter, being an alteration to the rules of the Association by the insertion of a new Rule 3A to bring about compliance with s.133AA of the Act, for decision by branch committees. The decision was in favour of the alteration but the matter was not submitted to branch committees by Federal Council as required by Rule 17 but by the Federal President, In the result, the Registrar gave certificates under s.139(4) of the Act as follows: Rules 15 and 37, on 21st October, 1975. Rules 14 and 39, on 17th May, 1976. Rules 3A, 9A, 20, 22, 24, 25 and 36A, on 17th September, 1976, The rules of the Association appearing to be in force following the last of the certificates given by the Registrar are hereinafter called "the new rules", A certificate given by the Registrar under s,139(4) of the Act does not validate an alteration to rules which has not been made in accordance with the relevant procedures laid down by the rules of the organization, Krantz v, Maynes (1967) 10 F.L.R. 134, A reference to sections 132 and 133 of the Act and Reg.. 115 of the Conciliation and Arbitration Regulations illustrate the fundamental nature and importance of rules of an organization. The rules constitute the very foundation of the registration and continued registration of organizations, c/f s.143 of the Act. Under Reg. 115 (1) (d) (xav) and (2), the rules of an organization are required to make provision for the alteration of its rules. The nature of rules of an organization was referred to insRoots v.-Mutton (unreported) 23rd March, 1978 where the Court comprising J.B. Sweeney, Evatt and Deane JJ. said: o/Teve -7- "The Rules of the Union comprise the compact between its members. In the absence of legislative provision to the contrary, there is no inherent power in the Union to alter or amend its Rules except possibly where the alteration or amendment is made with the agreement of all its members, Any power to alter them must, in the absence of legislative authority (and there is none), be found in the Rules themselves, Where the power exists in the Rules it must be fairly construed, Any purported exercise of it which goes beyond the ambit of the power when so construed or which disregards mandatory conditions which the Rules prescribe for the exercise of the power will be ineffective, If the power of amendment is given by directory provisions (as distinct from mandatory conditions) relating to the manner of its exercise, failure to comply substantially with those provisions will ordinarily invalidate a purported exercise of it (see-Scurr v. Brisbane City Council (1973) 133 C.L.R. 242 at 255-256)." Rule 14(b) of the rules of the Association confers a general power on the Federal Conference to alter the rules of the Association but "in the manner provided". Rule 56 confers specific powers and provides the manner by which the rules of the Association may be altered, namely by a resolution of the Federal Conference or by a plebiscite of the members of the Association, Some relief against strict compliance with Rule 56 in some aspects is given by Rule 56({c). On ordinary canons of construction, the specific power and procedure conferred by Rule 56 is the source of power to alter rules conferred upon the Federal Conference, the general power to alter rules referred to in Rule 14(b) requires the alteration to be made in the Manner provided by Rule 56, In other words, the provisions of Rule 14(b) do not, in the circumstances, add to the specific power conferred by Rule 56(a) and, in any event, the manner of altering rules as specified in Rule 56{a) must be followed. The procedure specified in Rule 56(a) is that the alteration to the rules must be by a resolution of the Federal Conference. The proviso 'to Rule 56 (a) emphasises the need for Federal Conference to know the terms of the proposed alteration before resolving to alter the rules, The only other method by which the rules of the Association can be altered is by a plebiscite of all members, The express provisions of Rule 56 prevent a delegation under Rule 14(i) of the power to alter rules, In any event, if there was a resolution passed at the 1974 Conference to delegate the power to alter the rules, 1t was not a delegation to any two or more members or to any Federal Body of the Association, There is no resolution of the Federal Conference -/8... altering the relevant rules of the Association to their form contained in the new rules, The decision of the branch committees to approve Rule 3A was not made in accordance with Rule 17. It follows that the purported alterations to the rules of the Association were not made in accordance with the relevant procedures laid down by 1ts rules and accordingly the alterations are invalid and of no effect, Under the new rules, the federal officers are elected by a secret postal ballot to all financial members of the Association, the delegates from each branch to Federal Conference are elected by a secret postal ballot of all financial members of the branch but candidates for that office are limited to members of the respective branch committees and delegates from each branch to Federal Council are elected by a secret postal ballot of all financial members of the branch. In September 1976, each branch committee of the Association was notified of the proposed alterations to the rules of the Association and of the application to the Registrar for his certificate under s.139(4) of the Act in relation to Rules 3A, 9A, 20, 22, 24, 25 and 36A, There is no evidence that before December 1976, the branch committees were notified that the Registrar had given a certificate in relation to the alterations affecting the election of federal officers and delegates to Federal Conference and to Federal Council, An ordinary Federal Conference of the Association was held in December 1976. The election of the federal officers prior to that Conference was conducted pursuant to the new rules. The election of the delegates to that Conference from the Victorian branch and the Tasmanian branch were conducted pursuant to the old rules. The New South Wales delegate was not elected to that Conference under either the old rules or the new rules. The evidence does not disclose whether the elections of the delegates to that Conference from the other branches were conducted pursuant to the new rules or to the old rules, At the 1976 Federal Conference, copies of the new rules were distributed to all delegates and thereafter, for all practical purposes, each branch and the federal bodies applied the new rules. There were annual elections of delegates to Federal Council conducted pursuant to the new rules. In 1977, the Queensland branch and the West Australian branch conducted elections for delegates to Federal Conference pursuant to the new rules, of Deas A special Federal Conference of the Association was held in December 1977. The Federal President and one of the Federal Vice-Presidents had each resigned their office some days prior to the 13th December, 1977, being the day on which the special Federal Conference was due to open, Attending the Federal Conference were ; the remaining Federal Vice-President, the Federal Secretary, the Federal Treasurer, one delegate from each of the Queensland branch and the West Australian branch, each of whom had been elected in 1977 pursuant to elections conducted under the new rules, one delegate from each of the Victorian branch and the Tasmanian branch, each of whom had been elected in 1976 to the ordinary Federal Conference held in December 1976 and under Rule 20 remained the delegate to the special Federal Conference in December 1977. Neither of the delegates attending from the New South Wales branch or the South Australian branch had been elected pursuant to elections conducted under the new rules or the old rules. Rule 13 of the rules of the Association provides that a quorum at Federal Conference consists of at least six members representing three branches. It follows that on any view of the rules, there was no quorum at the special Federal Conference held in December 1977. At the very most, there were five members validly elected and two branches only were represented. At the opening of the special Federal Conference, disputation developed as to an entitlement of persons to attend as delegates and as to other matters, There is no need to detail the evidence of what occurred at the special Federal Conference. It is sufficient to say that the resolutions concerning the next ordinary Federal Conference and the appointment of a Federal President, irrespective of any question as to validity arising from a lack of quorum have, by lapse of time and subsequent events, been rendered inoperative, . Following the special Federal Conference in December 1977, the Federal Council has continued its regular meetings. It continued to treat the new rules as the valid rules of the Association. Its members knew that a serious challenge to the validity of the alteration to the rules had been made. The absence of any formal record of a resolution of Federal Conference making the alterations to the rules should have been sufficient warning to the members of -/10... ' - 10 - the Federal Council that there was some substance to the invalidity claam. Tt is important that committees of management of organizations know and understand the nature and importance of the rules of their organization and that when any challenge to the validity of those rules is made and there appears to be some substance in the challenge, the committee should be prepared to facilitate the determination of whether an invalidity has occurred or not and if an invalidity has occurred, in appropriate cases, to seek rectification of that invalidity. The Federal Council ignored the challenge to the validity of the rule aliterations. It did not reply to letters from Mr. Kayne and from his solicitor seeking information concerning the alteration to the rules. It sent the correspondence to the solicitors for the Association and general delay resulted. In the meantime, at various meetings of the Federal Council, resolutions were passed on the assumption that the new rules were in fact valid and that the Association should proceed as if there was no challenge to the validity of its rules, Three only of these resolutions need be set out. At its meeting on 21st December, 1977, the Federal Council passed the following resolution: "That the Victorian, Tasmania, New South Wales and South Australian Branch Committees be requested to appoint Returning Officers for the election of Federal Conference delegates under the provisions of Rule 20, as amended, of the Constitution and Rules." At its meeting on 15th February, 1978, the Federal Council passed the following resolutions: "1, That an the interests of the smooth running of the Association and 2n an attempt to reach a period of equilibrium, Federal Council directs S.A. and Victorian Branches to conduct elections for Federal Conference delegates. 2. That Federal Council directs Victoria under Rule 25{}) and (0) to cease expending Association funds on the legal action they are currently taking." Under the rules of the Association the branches have control over branch funds. The resolution numbered 2 above can have no legal effect with respect to the funds of the Victorian branch. fill... t v - li- in 1978, the Federal President and a Federal Vice-President of the Association were elected in elections conducted under the new rules to £111 the casual vacancies in those offices. An ordinary Federal Conference is to be held at the end of November 1978, Elections for the positions of federal officers and of branch delegates to that Federal Conference have either been conducted or are being conducted pursuant to the new rules. Having received no response to requests for information concerning the alteration to the rules of the Association, on 19th April, 1978, Mr. Kayne, who 1s the President of the Victorian branch of the Association and a member of the Association, obtained a rule nisi in Matter V No. 11 of 1978. The rule was obtained under s,141 of the Act and called on the respondents, each of whom is a member of the Association, to show cause why certain orders should not be made, The substantial order sought was that the respondents perform and observe the rules of the Association by treating as null and void the amendments to the rules of the Association being the alterations to the rules already referred to. A number of the other orders sought arose from the resolutions passed at the special Federal Conference held in December 1977 and relateé matters arising from resolutions passed at subsequent meetings of the Federal Council but, for reasons already expressed, the Court does not make the orders so sought. For reasons about to be given, the Court did not make the substantial order sought by Mr. Kayne. By application dated 28th June, 1978, Mr. Croyston, the Federal President of the Association and a member of the Association, made application under s,171C of the Act for the determination of the question of whether an invalidity had occurred in the alteration of the rules of the Association being the alterations already referred to and, if so, for orders validating or rectifying any such invalidity, This application 1s Matter N No. 15 of 1978, The hearing of the two matters commenced on lith September, 1978 and wath the consent of all parties were heard concurrently. On the first day of the hearing, Counsel for Mr. Kayne requested Counsel for the Association to concede that an invalidity had occurred in the alteration of the rules of the Association but the ~/12.. -12- concession was not made. On the sixth day of the hearing, Counsel for the Association conceded that an snvalidity had occurred namely that any delegation of the power to alter the rules was not granted to at least two members or to any federal body, Rule 14(i). For reasons already given, the invalidity 1s more fundamental than that. The Court having found that an invalidity had occurred in the alteration to the rules of the Association, it became necessary to decide whether an order should be made as sought in Matter V No. 11 of 1978 namely that the respondents treat the alterations as invalid and of no effect or whether orders should be made in Matter N No. 15 of 1978 validating the alteration to the rules. At the conclusion of the hearing on 5th October, 1978, the Court made orders validating the alteration to the rules but the validation operated from different times depending upon the elections conducted and discharged the order nisi. Section 171C of the Act is contained in Part IXA of the Act. This Part was first inserted into the Act in 1974 and came into operation on 29th October, 1974. The purpose of the Part and in particular s.171C 1s to relieve organizations and members of organizations from the consequences of invalidity. As was said by J.B. Sweeney and Evatt JJ. in Re Australian Building Construction Employees and Builders Labourers Federation (unreported) 20th July, 1978 in relation to Part IXA of the Act: "It is clear that the group of sections constitute an attempt by the legislature to provide methods whereby the legal and effective functioning of organizations can be secured and to end the. difficulties which have arisen in arbitral jurisdictions where there has been a failure on the part of organizations properly to comply with the rules." Section 171C(1) enables an application to be made to the Court to determine whether an anvalidity has occurred in relation to a number of specified matters including an invalidity in the making or alteration of the rules of an organization, If the Court finds chat an invalidity has occurred, the Court is empowered to make such declaration as it thinks fit, Where the Court finds that an invalidity has occurred, s.171C(2) confers a discretion on the Court to do certain things 1uncluding the making of an order validating /13... - 13+ any act, matter or thing rendered invalid by or as a result of the invalidity, s.171C(2) (a). In the present case, there has been a full examination ' of the facts leading to the invalidity and of the facts subsequent thereto, Parties to the proceedings before the Court include the Association, federal officers and branch delegates to Federal Conference. We find that the alterations to the rules were made honestly even though not in compliance with the rules of the organisation and not in the manner provided by the rules. They were made in an attempt to bring the rules into compliance with amendments to the Act, Under the new rules, financial members of the Association participate directly 1n the election of federal officers and the respective branch delegates to Federal Conference and Federal Council. When the new rules were distributed in December 1976, there was no complaint by members of the Association as to their content and there was no formal claim then made that the alterations to the rules were invalid since the alterations ' were made not in the manner provided by the rules of the Association. ' There is st11l1 no complaint about the content of the new rules, the only complaint being that Federal Conference should determine the form and content of any alterations to the old rules in order to ensure compliance with the Act, Since the December 1976 Federal Conference, all elections within the Association have been conducted pursuant to the new Rules. If an order was made in Matter V Ne. 1l of 1978, grave uncertainties would arise among members of the Association relating to the validity of meetings of Federal Council and actions taken by federal officers and this could lead to further applications to the Court and the possible application of other sections contained in Part IXA of the Act. We are satisfied that the order made under s.171C(2) (a) will not do substantial injustice to the Association or to any member or creditor of the Association or to any person having dealings with the Association, s.171C(2) (b), and that it was not necessary that notice be given to other persons of the intention to make such an order, s.171C(2) (da). The order made under s,171C(1) relates only to the alteration of the rules of the Association and does not of itself apply to any other matter which may affect the validity of actions taken by the federal officers, the Federal Conference or Federal -/14... -~ 14 - Council. We were concerned to validate the elections to positions un the Association insofar as they might affect the election of the federal officers after the certificate given by the Registrar on 17th September, 1978, At the same time, we were concerned not to affect adversely those persons who were elected to office pursuant to elections conducted under the old rules at a time before notification of the certificatzon of the new rules was given at the December 1976 ordinary Federal Conference. For these reasons, the validation related to different dates. Insofar as the new rules affect the appointment of returning officers, the dismissal of elected officers from specified offices and the conduct of ballots 'by means of a secret postal ballot, the alterations to the rules operate from the same dates. The Federal Conference has power to consider the content of the new rules and, if thought desirable, to alter them in the manner provided by Rule 56, Orders made on 5th October, 1278 i= Matter V No. 11 of 1978 Rule Nisi discharged, Matter N No. 15 of 1978 On the facts before it the Court is of the opinion that an invalidity has occurred in the making or alteration of the rules of the Australian Broadcasting Staff Association and having regard to the facts proved the Court, in the exercise of its discretion, considers that it is not necessary to direct that any notice be given of thé intention to make the proposed order. Accordingly, the Court hereby determines and declares that an invalidity has occurred in the making or alteration of Rules 3A, 9A, 14, 15, 20, 22, 24, 25, 36A, 37 and 39 of the Association as certified by the Industrial Registrar by reason of non-compliance with the rules of the Association and the Court, being satisfied that the order herein made would not do L/15. ceheree ea neneea mae merece metteene ene tae eeu us Pentetmutrmirementnenen santa - 15 - substantial injustice to the Association or to any member or creditor of the Association or to any - person having dealings with the Association, SORDERS THAT the making or alteration of the aforesaid rules be, and the same is hereby validated in the following respects: 1. ain relation to the election of federal officers, from 17th September, 1976. 2, In relation to the election of branch delegates to Federal Conference and Federal Council from ist December, 1976, Liberty to apply, eo erie. Henry "TR Sweeney Guar, Rormeced Maywue Ailoluware (Assocwere. a Dares 6 "Ndecarler 19-78