In what circumstances will the court order production of the membership list of a Sikh society?

British Columbia, Canada


The following excerpt is from Viitre v. St. Peter's Estonian Evangelical Lutheran Church, 2010 BCSC 296 (CanLII):

In Sandhu v. Guru Nanak Sikh Gurdwara Society, 2001 BCSC 1543, Mr. Justice Vickers denied an application brought pursuant to s. 85 of the Society Act for production of the respondent society’s membership list. In Sandhu, the petitioner sought production of a membership list providing the name, address, membership number, telephone number, date of birth and nature of identification used by each member to obtain membership. The society had given notice of its annual general meeting. No issue was raised concerning the adequacy of that notice. The court found that the Society’s election committee had done nothing which could be interpreted as an omission, defect, error or irregularity. In these circumstances, in Sandhu at para. 6, the court held that it would be presumptuous to intervene and tell the committee how to conduct the election. The court left it to the committee to establish procedures to ensure that only members participated in the vote according to the bylaws.

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