Statement of Reasons

For the requisition of a Special General Meeting to consider the motion that

Kathy Webb be removed from the Committee of the Club

A letter dated 29th February 2017 was sent to Kathy Webb by the then Secretary of the Club,
Michael McCormick Smith, on behalf of himself and five other members of the committee asking her
to resign from the Committee and stating that if she did not do so a majority of the Committee
would resign, leaving the Committee inquorate and unable to transact any business. The letter was
drafted by David Steel and agreed by the other five members of the Committee involved, all of
whom agreed that the letter should be sent.
The contents of the letter were accurate at the time it was sent. Since then, Pete Jackson’s term of
office as Treasurer ended and so did his membership of the Committee: Andrea Ireson retired from
the Committee for personal and family reasons: and David Steel decided to remain on the
Kathy Webb refused to stand down from the Committee and as a consequence of her refusal a
requisition for a Special General Meeting, signed by more than the 15 members of the Club required
by the Rules, was delivered to the Secretary. Despite this Kathy Webb maintained her refusal to
leave the Committee and as a consequence Diane Layton-Smith (the new Treasurer) and Committee
member Anji Main resigned from the Committee during the AGM and the Secretary, Michael
McCormick Smith, resigned at the close of the Committee meeting that immediately followed the
AGM. The Committee therefore became inquorate and unable to transact any business other than
to call the SGM already requisitioned and the second SGM to appoint interim Officers and
Committee members to serve until the next AGM at which the results of the ballot for Officers and
Committee would take effect.
The reasons for the calling of the SGM are that by her attitude and conduct Kathy Webb has so
alienated some committee members that they were, and are, no longer willing to serve on the
Committee with her. Her actions, of which some examples are given below, have caused the Club
unnecessary and pointless damage, and her refusal to stand down from the Committee has led
inevitably to the resignation of Committee members and the result that the Committee has become
In the view of those putting forward the requisition Kathy Webb is no longer fit to serve as a
member of the Committee.
1. Rudeness towards foreign guests, Championship Show, October 2016.
This refers to the visit to the Championship Show by Mr Hamad El Ghanem and Mr Fahad Al Fahan.
Mr Fahan is the President of the International Aseel Arabian Saluki Center, and as such surely
someone we should be welcoming as a fellow enthusiast and overseas ambassador. They offered to
donate some additional prizes in a ceremony at the end, and most of us thought this would be an
interesting and enjoyable end to the proceedings.It is true that neither Mrs Webb nor the president,
Mrs Bryce-Smith, really wanted them to attend or to contribute to the show, and of course it was
their right to have the matter debated in committee. But having made the decision in committee to
welcome them and accept their offer of additional prizes, we expected that they would be received
in a courteous and dignified manner. In the event both Mrs Webb and Mrs Bryce-Smith were overtly

rude and offhand towards them, which was embarrassing to say the least for the committee
members who had been charged with their care and hospitality at the event. The guests themselves
were shocked, and there were complaints made.
In our opinion, the committee and the club were brought into disrepute by this behaviour, and both
perpetrators would be held to account for it in any decent society.
2. Mismanagement of Club seminar November 5th 2016.
Kathy Webb had taken on the organisation of this event, in conjunction with the President, Mrs
Bryce-Smith. Less than one week before the event was to take place we received notice from Mrs
Webb that not only would she not be attending, but that she had abdicated all responsibility for it.
She gave no cogent explanation, made no attempt at a handover of her responsibilities, and no
provision for the fact that her absence also meant that we would not have the required technical
equipment for the speakers’ presentations. It was up to other members to fill those gaps at very
short notice and considerable personal inconvenience, made worse by the cancellation of one of the
main speakers on the morning of the event, necessitating an arduous journey across country by train
by one of us in order to get the equipment to the venue. There was no apology or excuse from Mrs
Webb as to why she had not seen fit to attend. This made the committee look incompetent, and
again, complaints were received. In our opinion, such neglect of duty in a professional situation
would be grounds for demotion, if not dismissal. Why should it be tolerated it in this situation?
3. Failure to disclose matters of historical importance when considering an application for
It is not our intention to disclose the details, however this caused huge offence and brought the
whole committee under fire from a wide sample of the membership, several of whom felt so
strongly they threatened to leave the club. Although there was a committee investigation after the
fact, and the application for membership was upheld, even at that time the full details were still not
disclosed, and it became clear later that both Mrs Webb and Mrs Bryce-Smith had personal business
and interests with the individual concerned.
4. Continuing interference in the responsibilities of other committee members.
Mrs Webb seems to regard the position of chairman as a power base from which to instruct, micro-
manage, command and even bully other committee members. This behaviour extends to the
committee and beyond, to other individuals who have offered their services to help, and have been
met with intransigent behaviour and downright rudeness. Specific examples of interference and
obstructive behaviour, which the individuals concerned are prepared to speak to in detail, include
but are not limited to:

 The obstructive and disrespectful treatment of a willing volunteer (non-committee member)
over the provision of rosettes for the championship show
 Obstructing the production of an educational manual offered and written by one of the
seminar speakers
 Criticism of the chosen arrangement for printing of the schedule for the 2017 Limited Show
 Withholding of an appropriate hand-over of show management protocols to the incoming
 Badmouthing and criticising other committee members in public, at shows etc.

At a sit-down committee meeting of 4 th December 2016 several members of the committee took the
opportunity to take Mrs Webb to task over her conduct, and suggest that in view of her failure to
conduct herself appropriately, she should consider standing down from her position as chairman,
which she declined to do. However, she did agree to take on our comments about the role of
chairman, as a facilitating and organising principle, not as a hierarchical office of authority.
Subsequent to this she showed that she had not taken our comments on board in the following
 Further public acts of slander and defamation towards a committee member even after
being warned in the meeting that such behaviour could not be tolerated.
 Her tirade in a telephone conference against the show team over the production of the
Limited show schedule
Pains have been expended at all stages of these conflicts to deal with them in the honourable way,
face to face, and give Mrs Webb the opportunity to defend herself, offer explanations and account
for, if not actually apologise for her behaviour, which she has consistently declined to do. She has
never been kept in the dark about our complaints, neither has any campaign been conducted behind
her back. We have been forthright and open, and have involved the members only as a last resort.

We could all just have resigned at any time, and given up our positions on the committee, but that
we believe would have three negative consequences:
1) It would deprive the club of energetic, enthusiastic and productive volunteers.
2) It would, in our view, disadvantage members, who we believe have the right to a say in how club
business is conducted on their behalf.
3) Failure to confront such behaviour leaves others vulnerable to similar abuse in the future.

To us, it seemed worth making a stand.
Members of the Club must be aware that they will not be voting only on the question whether Kathy
Webb should, or should not, remain on the Committee but on the whole future of the Club and its
If Kathy Webb remains on the Committee, it is inevitable that the Committee will be dominated by
her and Marie Bryce-Smith. None of the Committee members who have resigned will stand for re-



Ref : 17/012/BFP
Your Ref: –
The Acting Secretary 15th May 2017
The Saluki or Gazelle Hound Club
28, Cootes Lane
Fen Drayton
CB24 4SL

Dear Sir
Our Client: Mrs Kathy Webb: Proposed Special General Meeting – 27th May 2017
We are instructed by Mrs Kathy Webb in respect of the above proposed meeting to remove her from the
committee of the Saluki or Gazelle Hound Club. We are in possession of a copy of the club’s Rules and
Constitution, the SGM Notice and various items of email correspondence.
We understand that there are complex issues involved here, but at this stage we concern ourselves only with the
legality of the proposed action, and the preservation of our client’s legal rights. What is being proposed is
This meeting is being called to expel our client from the committee. The effect of that would be personally very
serious for our client, affecting her international judging reputation amongst people around the world who know
of her, but do not know about the internal affairs of the club. They would naturally assume that she had
committed some crime, some serious breach of club rules, or some financial impropriety. As such the law gives
her certain rights in a process between her and the club which is clearly disciplinary in nature. She as a member
has a contract of membership with the club and as such is entitled to what is known as ‘natural justice’ in the
process proposed to expel her from the committee.
As part of that natural justice process she has certain rights as follows;
1) The right to know in advance of precisely what mis-conduct she is accused, by whom, and on what evidence.
All documentary evidence must be supplied to her in advance.
2) The right to take proper legal advice, and reasonable and proper time to do so.
3) The right to such reasonable time as is necessary to prepare a proper reply to the allegations whatever they may
be, which includes the right to having the SGM adjourned to do so.

Animal & Countryside Legal Consultancy
County Court Small Claims Representation
Litigation Investigations

The Old School, Melton Ross, Barnetby-le-Wold, Lincs, DN38 6DR

Tel: 01652 688697 Mobile: 07721 362627

In default of her being afforded these rights she can apply to the High Court to have the process set aside
as a breach of her membership contract and of her rights to natural justice. The court will not allow her to be run
through a ‘kangaroo court’ in this way without proper due process.
We now turn to the matter of costs. If this SGM proceeds and our client is removed, that process will be followed
by litigation against the club. If she is successful in getting the decision set aside, that may result in a very
substantial bill of costs against you. We need to point out to you that so far as we can ascertain the club is an
Unincorporated Association at law, which means that each and every member would be liable for any such costs.
The effect of that could be catastrophic for the members and the club, and in the past we have known of clubs and
societies being closed down as the result of such litigation.
Our client has no desire to see that happen, but will not tolerate being treated like this when she has done nothing
wrong beyond disagreeing with certain other members over certain issues. That is the nature of democracy.
Our client requires that the proposed SGM is either cancelled, or is adjourned to allow sufficient time for the
proper processes to take place, and for us to undertake a full investigation of the issues and advise our client
accordingly. Further it is imperative that your membership is advised of this correspondence as it may have
serious financial implications for them down the line, upon which they may need to take their own legal advice in
respect of the club’s actions on their behalf.

Yours faithfully

A. G. Fox Law



The Old Vicarage, Grove Road, Portland, Dorset DT5 1DB
Tel:01305 824133 Email:

A.G.Fox Law 31 May 2017
The Old School
Melton Ross Your Ref 17/012/BFP
Barnetby-le Wold
Lincs DN38 6DR

Dear Sirs

Your Client Mrs Kathy Webb

A copy of your email dated 30th May and addressed to Special General Meeting Requisitioners has
been passed to me. I am at a loss to understand why, as one of the Requisitioners, you did not send
me a copy direct.
I assume you have a copy of the Statement of Reasons for the requisitioning of the SGM. In case you
have not I attach a copy. This was sent, as requested, to the then Acting Secretary of the Club (Dr
John Hudson) on 18th May for circulation with the notice of the postponed SGM. Your client has had
ample time to prepare her defence and to take whatever advice she sees fit.
I will comment as follows on the Statement of Reasons.
First three paragraphs – these deal with matters of fact and are presumably not challenged. They can,
if needs be, be proved by complete email trails.
Fourth paragraph – again matters of fact to which the resigning members of the Committee will
Paragraph numbered 1. The decision to welcome the Arab guests is evidenced in the Committee
minutes. The rudeness shown towards the guests will be evidenced by oral evidence from those who
saw that behaviour. The complaint by one of the guests was made in a telephone conversation
between Fahad Al-Ghanem and Karen Fisher in which he said “I do not want to be treated like a piece
of fucking shit again by those two old women who run the club”.
Paragraph numbered 2. These are all statements of fact which your client knows perfectly well.
Detailed oral evidence will if required be given at the Special general meeting.
Paragraph numbered 3. A candidate for membership of the Club was proposed by your client (then
Chairman of the Committee) and seconded by Mrs Bryce-Smith, then President of the Club.
Applications for membership proposed and seconded by members of the Club in good standing are
almost invariably passed without debate by the Committee. The Chairman of the Committee and the
President are unquestionably members in good standing so they knew that the application would be

Both your client and Mrs Bryce-Smith were members of the Club in the 1990s and must have been
aware of the difficulties surrounding the application for, and refusal of, membership of the Coursing
Section by the applicant and her then husband.. Although the majority of the records of the Coursing
Section were recently destroyed in a house fire, the file relating to that person and her then husband
survives and will be put in evidence if necessary. The candidate concerned is a dog-sitter who, it is
understood, is regularly employed by your client and Mrs Bryce-Smith.
Paragraph numbered 4. Oral evidence will be given by the Club members affected by the behaviour
listed in this paragraph will be given at the Special general meeting. Your client knows perfectly well
what the details of the various allegations are.
The same applies to the continuation paragraphs, the contents of which are well known to your client.
Again, oral eye-witness evidence will be given at the Special General Meeting.
The final two paragraphs have to some extent been overtaken by events.
I will now turn to what is said in your circular email to the Requisitioners.
Third paragraph. As to your client’s reputation, it is pure speculation to suggest that people around
the world will assume that your client had committed some crime, etc. Please supply a copy of the
contract of membership you allege or, if there is no such printed copy, set out in detail the terms and
conditions of the contract.
1) The Statement of Reasons has been supplied, and the evidence for it set out above. The great
majority of the documentary evidence is already in your client’s possession (as Chairman of the
Committee). The evidence relating to the events in the Coursing Section in the 1990s will be supplied
if your client really wants all this dragged up again and disclosed to members of the Club in General
2) No-one has denied your client’s right to take legal advice if she wants to do so. She has clearly had
reasonable and proper time to do so, as evidenced by your letter.
3) Ditto. As you say, the SGM has been postponed (not adjourned – that can only happen after the
meeting has been convened) to a date to be fixed. That date must be before the second Sunday in July
and four weeks’ notice must be given, If that does not happen (and your client’s delaying tactics can
be interpreted as an attempt to prevent it) another SGM will be called.
Next paragraph 1). “Our prospects … are vanishingly small…” We have substantial support for the
motions before the SGM including some of the most senior people in the Club.
2). Nothing in the Statement of Reasons is other than provable fact and hence not defamatory. If your
client sees fit to issue legal proceedings these will be vigorously defended and may result in a
substantial order for costs against your client, including (for example) the costs of travel, hotel and
incidental expenses of numerous witnesses including our Arab guests.
3). You can “look” as hard as you like but your client has brought this situation upon herself and there
is no conceivable obligation upon anyone other than her to pay your costs .It was her decision to
instruct you. As to “very considerable costs”, I doubt it. Taking instructions and writing two
repetitive letters cannot have incurred very considerable costs.
“If this SGM proceeds…”. On what grounds will litigation be brought? The Rules of the Club and of
natural justice have been followed and if your client is removed from the committee, by due process
in accordance with the Rules and guidance received form the Kennel Club, there is no remedy in law
available to her.

“Our client has done nothing wrong…”. That may be her opinion but the facts show otherwise. To
attempt to dismiss her unacceptable behaviour as “disagreeing with certain other members over
certain issues” is a misrepresentation of the facts. The nature of democracy is that people can be
voted out of office if the electorate don’t like what they are or do.
As to her recent re-election, the SGM at which new Committee members were elected was attended, I
am told, by 21 members. That number includes your client and four of the Requisitioners, so the
actual number supporting your client was 16 – barely more than a quorum for the meeting, and less
than the number of people who signed the Requisition. To say that it is “quite clear that she has very
considerable support within the Society” would be laughable if it were not so pathetic. What are the
“considerable perils” you associate with challenging that by way of an SGM?
Enough damage has been done to the Club already. About 10% of the members have told us that they
will resign or not renew their subscriptions, and I expect others to follow. We are prepared to
consider withdrawing the Requisition if the Club will circulate to all its members (not just those in
the UK) your letter to the Club (which has already been printed in Our Dogs), the Statement of
Reasons, your letter to which this is a reply, and this reply.

Yours faithfully

M.J.McCormick Smith MA Solicitor
On behalf of himself and other Requisitioners