The High Court has ruled that Glenn Doyle was not a member of Crumlin Boxing Club in June 2017, when he was injured in an alleged assault during a club trip to Benidorm, Spain. The decision followed a trial of a preliminary issue and does not determine whether the club is liable for his injuries.
The club had argued that Mr Doyle’s membership prevented him from suing it. The court heard that members had signed forms waiving their right to sue the club and the Irish Athletic Boxing Association (IABA) where a claim would be incompatible with membership.
Mr Doyle had initially pleaded that he was a club member. In evidence, he said his status in 2017 was that of a coach, not a boxer, and that he had not paid subscriptions for several years. He had previously paid subscriptions as a boxer. The club’s witnesses said subscriptions were not enforced consistently and that coaches were treated as members, though the judge found there was no written rule requiring coaches to be members.
The judge examined membership forms, IABA affiliation records and witness evidence. The club had no written constitution or membership rulebook, and the court found it did not maintain the membership register required by IABA rules. Records submitted to the IABA named Mr Doyle as a coach in 2016 and 2019, but not in May 2017, shortly before the trip. The judge also found no evidence that he paid an annual fee, provided the required medical certificate or was recorded as a member at the relevant time.
The court accepted that Mr Doyle considered himself a member, took part in club activities and was treated by the club as a member. However, the judge concluded that those circumstances did not establish that he had been accorded legal membership under the club’s terms. The judge said the membership and IABA affiliation requirements were linked, including for insurance and participation in organised events.
The court therefore found that Mr Doyle’s membership had not been established and the club could not rely on membership to defeat the action. The judge left it to the judge hearing the full action to decide whether the club bears any liability for the injuries. The alleged assailant was not a party to the proceedings; the judgment said it appeared that he too may not have been a club member at the time.