Tuesday, 31 July 2012

" You would think they would have more than one goddamn toilet in this place ! "

Saturday, 28 July 2012


( From a membership total of around 140 , numbers suddenly plummeted to fewer than thirty. The timid , compliant and obedient members left on the books are listed below .)

Mr and Mrs Barlamb                 
Jack Dullard
Mr and Mrs Makepeace
Will B.Goode 
Evan Leigh-Manners
Patricia Placid
Mr and Mrs Mouse
Luke Deddpan
Kevin Keepstumm
Mr and Mrs Leaden
Nigel Saynowt  
Beryl Blankface
Mr and Mrs Head-Downe
Serene Ann Meek
Sue A. Peesin
Mr and Mrs Godley
Mr and Mrs Sitwell
Carl Mingway
Constance Smiling

Thursday, 26 July 2012

YET ANOTHER EXTRACT FROM THE BENIGN BC ZERO TOLERANCE POLICY DOCUMENT..... ( Volume 2 , Page 197 , Paragraph 246 , Sub-paragraph E )

Tournament Director's Duties :  
(e) : At the start of each event , the TD shall recite the following mantra , which requires all players to stand up , to raise their right arms and shout our their desire to honour the following Zero Tolerance Oath Of Best Behaviour :

You shall dutifully observe the club's zero tolerance policy by meeting all the best behaviour standards at all times .....  ( We will )
You solemnly promise on pain of death never to engage in any form of unacceptable behaviour ,  by suppressing both our negative emotions and inner demons.....( We will )
You demand that both swift and ruthless retribution will be inflicted on those who break the Oath ,  whenever any one of the 3458  rules laid down in the Best Behaviour Manual has been violated ......( Indeed  we do , indeed we do )
You will always love your partners and opponents irrespective of their personality defects , their woeful lack of ability and low down cheating ways......( We will ) 
You will forever strive  to move and speak in a completely uniform and wooden way , such that all standards of conformity can be universally met . ( We will  )
Let dullness , tedium and boredom be our sacred goals.....( Yes , yes , yes ) "  

AN EXTRACT FROM THE BENIGN BC ZERO TOLERANCE POLICY STATEMENT....... ( Volume 3 ,  Page 347 , Paragraph 486 , sub-paragraph  F )

" Offering Congratulations :

These are completely forbidden in all circumstances . Attempting to offer congratulations , no matter how small , will result in the errant member forfeiting his/her membership rights immediately ,  and permanently.
Congratulating oneself will be regarded as a provocative act of sickening smugness , solely designed to get all the other players' backs up .
Congratulating one's partner will be deemed as an act of unforgivable  rudeness by innuendo ,  suggesting that the opponents bidding and play of the cards was grossly inept and woeful .
Similarly , congratulating one's opponents will be treated as a complete snub and unwarranted criticism of partner's wretched inability to engineer their downfall in either the bidding or the play. "

Wednesday, 25 July 2012

A SCENE FROM THE BENIGN BRIDGE CLUB USA..... ( where all the members fully believe in and endorse the Zero Tolerance Doctrine , imposing upon themselves very strict standards of best behaviour )

East : Sometimes I feel as if I am in a morgue such is the stillness and tranquillity of the place
West : Yes....ever since we embraced the zero tolerance policy everyone has become most pleasant and agreeable.....why just the other day when I accidentally trod on my partner's foot he thanked me profusely for reminding him that his bunion was still causing him great discomfort
North :  Please forgive me for being a bit of a doubting Thomas......but don't you find the atmosphere here stifling with its tedious , monotonous, flat , dreary platitudes and feigned bon hommie ?
South : Oh no.....I would much rather receive a feigned smile of welcome or approval than a mouthful of barbed comments and verbal abuse
North : Indeed.....but surely my good friend it is better to be honest with one's feelings than having to bite one's lip in an attempt to suppress them
East : Allow me to please interject.......there is no need to harbour negative feelings against others if one sets out to be congenial , caring, tolerant and sympathetic. Learning to forgive others is what the bible preaches.......
North : I'm terribly sorry but I am becoming more and more concerned that since the introduction of zero tolerance policies , everyone is this goddamn friggin' place....except me.... is wearing a straitjacket of conformity.......which in my book is a sign of madness !
West : Director.....director......
Director : What's the problem ?
West : North use two rather unpleasant words...
Director : Really....what were they ?
West : Goddamn ...and.....friggin'
Director : North .....I'm afraid you are no longer a welcome member at this club..... you are to leave the premises immediately
North : Hold on ...you just read those words from a script......are you an automaton or what ?
Director : North ......I'm afraid you are no longer a welcome member at this club....you are to leave the premises immediately
South : I love you North
East : So sorry to see your membership at this club end this way
West : I sorry I got you into this bother.....I really am
North ( mumbling under his breath ) : What a load of tossers ......I'm off to join the Slaughter House Bridge Club where people are real .....exciting......unpredictable.....and inspiring


Yes...unbelievable things happened at Johnny's table on board 23 . His partner had been dealt a yarborough , Johnny had opened 1NT on a ropey  KJ10x.....Kxx....Qx.....QJ10x , and his expert opponents sailed into a 6NT contract played by South.
In a matter of seconds declarer had rattled off 8 top red suit tricks picking up both Johnny's heart king and diamond queen in the process. By trick 6 the only honours left in dummy were the AQ of spades , and so Johnny's first discard was naturally the 10 of spades. On tricks 7 and 8 Johnny calmly played the QJ of clubs , patently aware that declarer had both the AK of clubs in his sweaty mitt. 
Johnny's vision was now rewarded when declarer played off the AK of clubs , under which the 10x was played. Then when South volunteered the club 8 it was a rather surprised partner who popped in with his 9 to win the trick ! With a spade fired back a forlorn declarer played the queen only to see a triumphant Johnny swoop in with the King to defeat the contract.
So when a kibitzer queried whether declarer , knowing Johnny to be out of clubs but with spades left to the KJx , ducking a spade all round would set up an end play in spades . The answer was swift as it was obvious. If partner held the 98 of spades, which he did, then the 9 would force the play of dummy's queen . So having taken this trick with the king, a return of a spade to partner's 8 will force out dummy's Ace to set up the jack for the setting trick.
Well, I say hats off to Johnny for quick thinking , spotting the danger , and providing the best example of unblocking play I've seen in years......   

Monday, 23 July 2012


Carp : Tell me doctor do you consider some male bridge players to be overly aggressive ?
Dr.J : Sadly yes.....in fact far too many male bridge players  start to display extremely aggressive behaviour the moment  they sit down to play bridge....
C : But isn't the modern game all about " aggression " ?
Dr.J : I agree....it seems the need to be aggressive in competitive matches is both expected and approved. Men in particular are compelled to bid aggressively , make attacking leads , psych out their opponents , inflict all manner of uppercuts , coups , penalty doubles and squeezes. In reality this aggression turns out to be nothing one than one-upmanship . However ,  
aggression is the form of bickering , harassment , haranguing, throwing insults and other forms of threatening behaviour has also become essential part and parcel of the game within this small group of objectionable men
C : But why men ?
Dr. J : Aggressive behaviour can be traced backed to their upbringing. As boys , pressure is exerted upon them to be tough , never to be seen crying ,  to accept that the best form of defence is attack , and to always go for the jugular. Forever reminded how tough and mean the world is out there , boys are told to stand firm and fight their corner. 
C : So how come we don't see players exchanging blows with one another over the table ?
Dr.J : The conditioning process usually directs men to channel their aggression into ritualised forms of non-physical combat . Indeed , it is highly desirable.....and sensible ....to direct  aggression at those who can be classified as non-entities , strangers , aliens, big  nasty Goliaths or any other legitimate targets.  Opponents at a bridge table fit that bill to a tee .
C : But does bridge always have to be played in battle-like conditions ?
Dr. J : No...I would say that the bridge arena is more like a jungle where predators and prey are thrown together . The instinct of the predator is to stalk and savage the weak ......and when predator meets predator.....then it becomes a fierce battle for supremacy
C :  So please explain to me why it is a player can become aggressive towards his partner ?
Dr. J : That's easy ......when  partners bid and play the cards in a way the aggressor doesn't approve of.....that person is acting like a stranger .....a friend and ally of the opponents. This creates a highly volatile situation 
C : So do you believe that bridge environment has become an outlet for a man's aggressive tendencies.... or perhaps a catalyst ?
Dr. J : I suspect both.....
C : Can zero tolerance and best behaviour policies tackle this problem ?
Dr.J : In a word .....NO.....because the human condition only permits the demons to be kept at bay for short periods....... for instance keeping a lid on a boiling pot can only be done for so long....
C : Well so long then.....I'm definitely  off
Dr. J : Hold on........I could recommend you a good deodorant....

Friday, 20 July 2012

( At a packed AGM Bigot-Johnson is accused of botching the latest expulsion of a Pantopod  as this resulted in the club getting into itself into serious financial difficulty . One angry member turned on Bigot to explain his actions .)

AM :  Bigot....why didn't you listen to the voice of reason who begged and pleaded with you not to sling Penny Pantopod out of the club ?
B-J : ......Because the interfering toss pot talked a load of crap
AM : But he raised valid points of concern based on established legal principles laid down by judges about due process and fair procedure
B-J : Well , they too must be full of crap....we had damn good reasons for getting rid of Panto
AM : That may be so....but the process undertaken by the committee , both steered and directed by you ,  was completely flawed......especially as you failed to listen to the voice of reason......
B-J : As I said before .....this traitorous dog was full of crap........a despised and despicable Panto sympathiser
AM : Even if this observation was true.......... that doesn't necessarily mean he talked rubbish......clearly he spoke with a great deal of informed legal knowledge , wisdom and common sense....
B-J : Listen muppethead....we on the committee knew best....he was just being an awkward and objectionable rebel  
AM:  Well , didn't the voice of reason point out the obvious bias was being shown against Penny Pantopod during the disciplinary proceedings ?.......
B-J : That was an insult against the good names and reputations of the decent fair minded people on that committee who man to man wanted to send out a lynch party to do Panto in there and then
AM : Yet there was overwhelming documentary evidence to prove that bias against Panto was extreme and menacing
B-J : That's all clap trap....
AM : But these documents all contain statements made by you and other leading committee members , admitting how much you hated the woman and wanted rid of her.....months... even years before...... the actual incident which precipitated the flawed disciplinary hearing....
B-J : Oh....bugger
AM : And why didn't you listen to the voice of reason who begged you from start to take the dispute to arbitration rather than seeking your day in court ?
B-J : Because....the voice of reason was the voice of smart arse  sanctimonious know all who only talks crap.....and there was no way on God's earth were we going to change our decision......and do anything that prat suggested
AM : So please explain the membership gathered here tonight why you have now decided to take this dispute to arbitration ?
B-J : The circumstances have changed.....
AM : Therefore, the voice of reason was right after all ?
B-J : Absolutely not.....because at the time he said it  the idea was ludicrous......however today , with the prospect of the club facing serious financial trouble....  the committee quite rightly believes that arbitration makes good sense
AM : Tell me.....do you ever listen to other voices who offer good advice.........?
B-J :  Only one.....
AM:  And whose voice was that ?
B-J : That of little man who lives inside my head...
AM : And who might he be....
B-J : The King of the Potato People of course......

" I get  the distinct impression this club doesn't approve of visitors complaining about all the cheating that goes on........"

Thursday, 19 July 2012


" I guess the club's committee is anticipating an even bigger clear out of undesirable members......"  

Monday, 16 July 2012

(  Having already brought the Slaughter House BC into disrepute on several previous occasions , Bigot-Johnson yet again found himself up before the Magistrates to face charges of a rather despicable nature . Bigot of course elected to defend himself . )

B-J : What the blue blazes is this prosecution all about ?......I run bridge club not a doss house or a cesspit
Prosecutor ( P) : We will come to the charge in question in due course.......All I want from you are just honest answers to a few simple questions.....
B-J : If you insist .....fire away....
P : Is it true that you and your committee spies sift and root through the garbage bins of your members in order to obtain all manner " of dirt " on them ?
B-J : Yes.....and why not.....we cannot afford to have members in our club who might be up to no good
P : And is it also true that most of the important committee decisions are made by the chosen few who secretly meet up in dark corners and corridors ?
B-J : Of course........that's the way that all organisations carry out their political decision making
P : But please tell the court the number of times ordinary members have come to the club in good health only to leave with all manner of illnesses and complaints
B-J : Too bloody right..... crikey ,  the complaints we get to hear about you could fill a book 
P : So you don't deny then that way you , and your lackeys ,  run the premises is the sole cause of too many members leaving the place desperately sick and upset ....and feeling like death warmed up ?
B-J : That's what  happens when you're playing bridge in a highly volatile and competitive environment  
P : And is it not the case that you and other committee members scurry around in packs ,  looking to feed on others, and always sinking their teeth into a whole load of things that are of no concern to you
B-J : Yes....yes...but what are all these questions leading up to ?
P : In short Bigot....you have allowed your club house to be infested with vermin...... meaning that you have failed to keep the premises free of pests and rodents ......allowing them to run amok as an ever growing environmental health risk
B-J : Oh...
P : Indeed, following dozens of complaints a team of undercover officers visited your premises  only to be amazed at how many big nasty rats there were .....all running about in the open. The place was overrun with them.....it was horrible.....the health risks were immense .... and what's more these poor souls all left the premises feeling seriously ill and in need of urgent medical attention..
Magistrate : I've heard enough... this is the most flagrant breach of environmental health legislation I have ever come across....how is it that this bridge club has become a breeding ground for such vermin ?.....The place needs to be shut down.....or better still.....burnt to the ground
B-J : Would you mind  issuing  this order after we've had our big pairs competition.... planned for this weekend ?
Magistrate : No...
B-J : Bugger....

Saturday, 14 July 2012

BRIDGE BOOKS ONLY AVAILABLE ON THE BLACK MARKET...... ( Inside information by Pun ) 

  • They Dragged My Partner Away Screaming..........E. B. G. Bees
  • Yes, I'm Part Of That Four Man Team..................Bob Sleigh-Ryder
  • Like Magpies They're Only After The Silvereware....Jack Dawes
  • What Was His Excuse For Not Turning Up ?....Joel E. Buoys-Howtin
  • She's In For A Right Good Hiding Partnering Him.......Willy Tanner 
  • I've Got No Faith  In TDs....................................Tobias Foreshaw
  • He's A Past Master At Peeking...............................B. D. Hyde
  • How To Be The Linchpin Of Any Team...................Ann Carman
  • There's Only One Game Better Than Bridge..........Tex  S. Oldham
  • Now That Match We Won At A Canter....................Hanz Downe
  • Why Do Players Keep Calling Me " Dickhead " ?....Richard Boss     

Friday, 13 July 2012


( Just lately Bigot-Johnson has been enjoying unparallelled and unprecedented success at his club, winning one event after another . Indeed , this complete reversal of his fortunes can attributed to only one thing : the recent imposition of 10 unholy commandments , as shown below . )

1. No player is allowed to open the bidding before the Club Chairman , Bigot-Johnson 
2. Even when the Chairman has opened the bidding , opponents can only enter the auction with simple overcalls
3. Any opponent who uses an artificial system bid will be shot
4. Any player who makes an unnatural bid will be washed and cleansed with unholy boiling water
5. Opponents are not permitted to " double " the Chairman's bids under any circumstances, as such bids would be viewed as undermining Bigot's bridge integrity and wisdom 
6. Opponents must not execute a squeeze or coup against the revered and pacifist-minded Chairman , as these would be classified as unwanted acts of open aggression and rebellion
7. Any partner of Bigot must always tell him beforehand when he/she intends to psyche
8. Opponents are not permitted to call the TD over , whenever Bigot is at the table ( since any allegations of wrongdoing will be automatically deemed as false , defamatory and malicious )
9. Opponents are obliged to play all their low cards first , when following suit to bigot's play
10. And should our esteemed Chairman record a poor score , then every avenue must be explored to have the board scrubbed     

Friday, 6 July 2012


Thursday, 5 July 2012


The editorial team, which is " I " and all my other selves, want to make it known that our views and opinions may not reflect those held by the bridge world at large. Should any of the content on this blog offend or upset new and old readers alike , this is purely the result of inadvertence and/or innocent oversight, and we therefore offer our  humble ,  grovelling apologies for both past and future aberrations.
Mind you , the editorial staff firmly believe there is nothing in their articles worth getting into a strop over . So what if we take a cynical look at the absurd and crazy things which take place on a daily basis right infront of our very eyes . Why shouldn't we ? Whatever views we express are all our own , whether they are tongue-in-cheek or genuinely felt criticisms about certain unpleasant and unacceptable aspects of the game , and its administration. Nevertheless the overriding aim of this blog is to combine law , philosophy , psychology and a right good dollop of toilet humour into the world of bridge, if only to make it appear even more bizarre than it really is.
Life's too short to get yourself upset , miffed or uptight......it's far better to lighten up and laugh at ourselves . Why not consider with a rather wry smile that underneath the attempted satire and irony there are hard truths that we must all face up to. The alternative it seems is to live a lie and remain in self-denial.

( Bigot -Johnson yet again found himself in court having to defend his decision for expelling one of the few remaining Pantopods still registered as members at the Slaughter House Bridge Club. Representing himself as always ,  Bigot had decided to call up 18 witnesses to back up his claim that Pippa Pantopod was a troublemaker and rebel, hell bent on making his life difficult as Chairman. However, unfortunately for Bigot the judge was having great difficulty  in getting a proper grasp of what was really going on , as the following extract reveals . )  

Judge : Bigot…who’s your first witness ?
B-J :  Shona Mycock….

Judge : Be that as it may…I trust you didn’t shock her
B-J :  S…H…O…N….A …..Shona
Judge : Oh sorry….
( Several minutes later )
Judge : Any other witnesses ?
B-J : Yes …Paul Mycock
Judge : Have you no decency Bigot…..this is a courtroom…..can’t you wait till we are alone
B-J :  P…A…U…L…..Paul
Judge : Oh dear…I’ve done it again
( Several minutes later )
Judge : How many more witnesses ?
B-J : Three….
Judge : Oh this is getting tedious......who is it this time ?
B-J : Rob Mycock
Judge : I’ve told you once…..wait till we get into chambers !
B-J :  R…O…B……Rob
Judge : I’m so sorry …it’s just my filthy mind leading me to come to the wrong conclusions
B-J : No problem your honour…..it’s your prerogative…..but I must warn you I have two more family members to call up as witnesses
Judge : Who they are ?
B-J :  Aaron Mycock…
Judge : That happens when you reach puberty ….
B-J :  And Freida Mycock..
Judge : Might well be….if it’s a whopper
B-J : I give up….

Tuesday, 3 July 2012

BIGOT'S AT IT AGAIN..............

( After opening 1C on a flat 3442 zero count ,  Bigot then had to face a barrage of abuse after his opponents finished up in a 3NT contract making plus 2. They were both aware that all around the room a small slam in clubs had been bid and made in their direction. )

Opponent : You psyched......
B-J : No I didn't.....it was a prepared club
Opponent 2 : But your partner didn't alert....
B-J : He obviously forgot it was on the card.....
Opponent 1 : Apart from only having 2  card club suit your hand had no bloody points
B-J :  The favourable vulnerability favoured a frisky bid
Opponent 2 : This is an outrage......we've been damaged by your bid
B-J : Might I point out that making 660 is a far better score than those pairs in 5C plus one
Opponent 1 : But you kept us out of 6C and a score of 1370 ..
B-J : You kept yourselves out of a slam....NOT ME !
Opponent 2 : How come ?
B-J : Listen muppethead.....what would you bid if your RHO opponent opened 1C , when you're sitting there , red against green ,  holding AKQ....AKQJ10...A....AKQJ in your hand ?
Opponent 2 : 7NT of course ....
B-J : Exactly....and therefore you are your partner with a combined 33 count and 6-5 club fit should have the bidding nous to reach the obvious match point contract
Opponent 1 : That's your opinion ...but I'm still going to call the TD over
B-J : I wouln't if I was you......it's Ronnie
Opponent 2 : Yes partner.... he's right....best not to......
B-J :  So onto the next board then...

( Bigot first to bid looks down at his 4144 three count .... and immediately reaches reaches for the1H card ))

Sunday, 1 July 2012

THE HEARING RULE ………. ( Part 2 of Professor Hu Chi Ku chi’s article )

In a nutshell, if a club’s disciplinary process is likely to result in the expulsion of a member , it seems imperative that he or she should be given an initial hearing . If a decision to expel a person is taken in his/her absence presence , then there is real ammunition for a lawyer to argue , and establish a claim that procedural fairness may have been compromised.


Problems inevitably arise if club members have agreed to be bound by their own constitutional rules on disciplinary procedures , which then begs the question : why should the courts intrude and impose some different obligations ? However, before that question can be answered , the courts will usually consider several other isues first.


The starting point now appears to be whether or not the courts view the expulsion as wrongful, rather than acknowledging that the club committee may have acted contrary to its own rules. Courts are quite prepared to accept that club’s constitution could well have inadequate systems for dealing with disciplinary matters , falling short of what the common law might otherwise require , but they are more ready to intervene when procedural fairness is missing. Even if members have agreed to abide by an inadequate set of internal rules, they haven’t agreed that these rules can be flouted , or carried out in a grossly unfair way.


In Lee v The Showman’s Guild of great Britain (1952 )  Lord Denning took the view that procedural fairness considerations should also apply to cases involving voluntary associations . Then in 1980 , in a case called Calvin v Carr , which involved the Australian Jockey Club, the English Privy Council dealt with an appeal coming from Australia. The Law Lords considered whether the rules of procedural fairness had been breached in suspending a horse owner from racing , without even specifically asking whether the rules applied.


This ruling was backed up in Plenty v The Seventh-Day Adventist Church , in which a committee arrived at a decision after a most remarkable and convoluted set of proceedings. Here the Supreme Court of South Australia agreed that procedural fairness also applied to the internal affairs of a church committee.  Although the church had good rules , the committee failed to provide sufficient particulars of the charges against Plenty, and by doing so failed to meet the requirements of procedural fairness.


The hearing rule certainly comes into operation whenever the issue concerns a club member's valuable rights , or loss of them , as in the case of expulsions. But what then makes a hearing fair ? This question can only be answered by a judge, who will attempt to take an objective view as to what degree of fairness was deemed necessary in that particular case . In practice there has to be something inherently and fundamentally unfair about the procedure for courts to intervene.


A hearing before an impartial fact-finding and decision-making committee members is of course an essential requirement. That needs to be followed up with the person , whose rights might be affected by the outcome , being given the opportunity to know what was being said against or about him.

Certainly, a person should be entitled to have an opportunity to put their case to the disciplinary committee before the punishment is decided upon. No one can demand the opportunity to examine every nuance of every thought that the decision-maker might be entertaining , or be given notice of every point or matter , however minor, that might be relevant : just the opportunity to hear…. and be heard. Procedural fairness  surely entitles a person to be told , broadly speaking , what the complaint was , the disciplinary charges laid against him/her , the findings of the fact-finding committee members , and the reasons behind the sanction being considered.

A fair hearing should also impose a sanction solely  based on established evidence , and /or an explanation of it, if only to give the accused an opportunity to challenge its severity , before putting in a plea for mitigation. Even if guilt has been admitted to the charge(s) laid down, the member in question should always be given a hearing .

But then there is the thorny problem of whether the accused has a right to a hearing , when it transpires that the constitutional rules stay silent on such an issue , or allow the committee to offer a hearing within its discretionary powers.   In my opinion , there is a strong moral argument for a right of hearing to be declared as  automatic , when expulsion is on the agenda. For instance, if a committee conducts a hearing without the person being present , simply because “ there was no point to him being there “ , then the victim of such arrogance and unfair practice should be able to seek legal redress .

Another obvious requirement is that the club committee must provide adequate notice of the meeting ( at least 3-4 weeks in advance ) , with a willingness to rearrange alternative dates if the person cannot attend the first scheduled hearing. Any efforts by the committee, designed to make life difficult, awkward and problematic for the troubled individual , might well be construed as unfair , if not malicious .
Indeed , it makes good sense for committee to go out of their way to make sure the person involved actually attends the hearing , if only to prove that everything was fair and above board. Committee members are also advised to step down when personal bias against the person cannot be denied. It also wise and prudent to allow the person the right to have a fellow member and friend in attendance , if only to provide moral support and back up. These simple things would help convince any court that the disciplinary procedure was carried out in a fair and proper manner.

Club committees , therefore , are well advised to be accommodating and understanding throughout the whole disciplinary process , if only to demonstrate their determination to act in accordance with rules of natural justice. The manner in which this process is carried out should aim to convince an independent onlooker that a spirit of reasonableness had prevailed from start to finish . This way the courts are more likely to ignore any ongoing grievances of a disciplined member, in that why should there be intervention ,  when a just and fair process has already taken place. It is only in circumstances where the process has all the hallmarks of a kangaroo court that a judge will come to the aid of a wrongfully expelled member, as in a recent Scottish judicial review case Innes v Dullatur Golf Club ( 2011 ) .