The Manly Warringah Sea Eagles have filed a legal defence asserting that young player Keith Titmuss contributed to his own death by failing to disclose his fitness level and by not stopping a pre-season training session when he felt unwell, according to court documents obtained by Australian media. Titmuss, aged 20, collapsed during an indoor workout at the club’s Narrabeen facility in November 2020 and later died. A 2024 coronial inquest concluded the cause was exertional heat stroke, finding a pre-existing heart condition unlikely to have played a part.

The family of Titmuss is suing the club for damages, alleging negligence including a failure to implement the NRL heat policy. In its defence, filed in the NSW Supreme Court, the club states that “NRL training is inherently dangerous” and that any injury or loss was “caused or contributed to by the deceased’s own negligence.” The club alleges Titmuss did not properly manage his weight and diet during the off-season and that players had been instructed to inform coaching staff if they were feeling ill or unable to cope with physical demands.

Disputed accounts of the training session emerge from the filings. The outdoor sprint tests were followed by an indoor cardio circuit inside a dojo that was not air-conditioned. The temperature was about 21 degrees Celsius but humidity was 92 per cent. The family’s statement of claim asserts that large floor-standing cooling fans were present but not switched on; the club’s defence says the back doors were open, multiple fans were in place, and hydration breaks were enforced. The family further alleges the club failed to provide a safe work system, did not follow its own heat policy—instituted after a former player suffered heat stroke in 2017—and did not properly hydrate the players. The club says a fitness test four days earlier had shown “no red flags.”

The legal action remains before the court. The Sydney Morning Herald, citing sources not authorised to speak publicly, reported that the Titmuss family had received a payment of about $1 million from the NRL and the club’s insurer. The Sea Eagles have stated they remain “deeply saddened” by the death and welcomed the opportunity to learn from the coronial inquest.