WILLIAMS v Australasian Meat Industry Employee's Union (NSW Branch)

The parties to this proceeding were Mr. Williams, the applicant, and the Australasian Meat Industry Employee's Union (NSW Branch), the respondent. The dispute concerned the respondent union's alleged contravention of section 180 of the *Industrial Relations Act 1996* (NSW) by failing to provide Mr. Williams with a copy of the union's rules and by failing to provide him with a copy of the union's annual financial report. Mr. Williams sought orders from the Industrial Relations Commission of New South Wales for the union to comply with these statutory obligations.

The primary legal issue before Dowdy J was whether the respondent union had breached its statutory obligations under section 180 of the *Industrial Relations Act 1996* (NSW) by failing to provide Mr. Williams with a copy of the union's rules and its annual financial report. This required the court to consider the scope of the union's duty to provide such documents to its members and the circumstances under which such a duty is triggered.

Dowdy J found that the respondent union had indeed contravened section 180 of the *Industrial Relations Act 1996* (NSW). The court held that the union had a clear statutory obligation to provide a copy of its rules to any member upon request, and similarly, to provide a copy of its annual financial report. The evidence demonstrated that Mr. Williams had made requests for these documents, and the union had failed to comply. The court applied the plain wording of section 180, which imposes a positive duty on registered industrial organisations to furnish these documents to their members.

The court ordered the respondent union to provide Mr. Williams with a copy of the union's rules and a copy of its annual financial report within 28 days of the date of the order.