Ratio Decidendi
A sports regulatory body exercising quasi-public disciplinary functions must comply with the rules of natural justice. The relationship is contractual, and the court will imply a term that the body will act fairly.
Fapte
A licensed jockey was warned off by the Jockey Club following a disciplinary finding. He challenged the decision, arguing procedural unfairness. The Jockey Club argued its relationship with licensees was purely private and not subject to judicial review.
Rezumatul hotărârii
The Court of Appeal held that while the Jockey Club was not amenable to judicial review, the contractual relationship with the jockey was subject to implied terms of fairness. The court would intervene to ensure the disciplinary process was conducted fairly.
Citate cheie
"The relationship between the Jockey Club and its licensees is contractual. But the court will imply into that contract a term that the Club will act fairly in exercising its disciplinary functions."
— Richards LJ
Tratament ulterior
Applied to other sports disciplinary bodies including the Football Association and UK Athletics.