Harrington v Coote (No 2)

Harrington v Coote (No 2) concerned a dispute between members of a religious organisation, the Uniting Church in Australia, regarding the management and powers of the church. The case came before the Full Court of the Supreme Court of South Australia.

The central legal issues before the court were whether the court had jurisdiction to intervene in the internal affairs of the Uniting Church, and if so, what principles should guide the court's exercise of that jurisdiction. Specifically, the court considered the extent to which it could review decisions made by church bodies concerning the property and governance of the denomination.

The court reasoned that while courts are generally reluctant to interfere in the internal governance of religious bodies, they retain jurisdiction to do so where there is a dispute involving property rights or where the internal processes of the church have been conducted in a manner that is contrary to natural justice or the church's own constitution. The court applied principles of contract and trust law, viewing the church's constitution and regulations as creating binding obligations between its members and governing the use of church property. The court emphasised that its role was not to determine theological matters but to resolve legal disputes arising from the church's organisational structure and the rights and obligations of its members.

The court ultimately found that it did have jurisdiction to hear the matter and proceeded to consider the specific claims made by the parties.