Manly Warringah NRL club has claimed rising star Keith Titmuss allegedly contributed to his own death by failing to manage his fitness, weight and diet before training began.
The 20-year-old died in November 2020 after collapsing during his first field session of the Sea Eagles’ pre-season at the Sydney Academy of Sport in Narrabeen.
His family launched a multimillion-dollar legal action against Manly in the NSW Supreme Court, alleging the club was negligent and failed to implement adequate protections against heat illness.
However, court documents reveal Manly denies responsibility and claims Titmuss contributed to his death by not telling coaching and medical staff about his physical condition following the off-season.
‘NRL training is inherently dangerous,’ the club said in its defence.
‘Any injury, loss and damage suffered by [Titmuss’s family]… was caused or contributed to by the deceased’s own negligence.’
Keith Titmuss (pictured) died aged 20 after collapsing during a Manly Sea Eagles pre-season training session in November 2020
The rising rugby league player, pictured with Jason Saab, had progressed through Manly’s junior system but never played a senior NRL match
Titmuss’s family launched legal action in the NSW Supreme Court, alleging the Sea Eagles breached their duty of care
Manly alleged Titmuss failed to train or diet properly during the off-season and did not stop exercising when he began feeling unwell.
‘Players were instructed… if they were feeling ill or feeling like they were not coping with the physical demands [that] they were to inform coaching staff,’ the club said.
The Sea Eagles added in its defence that Titmuss ‘failed to sufficiently manage his health, weight and diet in the off-season ahead of the training session’.
The club further alleged he did not properly investigate any health conditions that could have placed him at greater risk and he ‘failed to communicate his condition or fitness to coaching staff at the training session’.
But Manly acknowledged the club had conducted fitness testing on Titmuss four days before his death and found ‘no red flags’.
The family’s statement of claim alleges those tests showed ‘the deceased’s comparative level of fitness was the lowest among the training cohort’.
Training began outside at 9am on November 23, 2020, with the temperature recorded at 21.3C and humidity reaching 92 per cent.
The outdoor session, which included repeated high-intensity exercises, lasted between 90 and 100 minutes.
The Titmuss family alleged large floor-standing fans inside the Dojo were not operating during the fatal training session
Titmuss’s mother, Lafo (pictured), said the family launched its court action because it was determined to secure justice
Players then jogged about 800m to a dojo, where they completed a ‘100 passes drill’ and a cardio circuit featuring burpees, bear crawls and ‘fireman carries’.
That indoor component lasted between 15 and 20 minutes.
‘The Dojo was not fitted with air conditioning,’ the family’s claim said.
‘There were a number of large floor-standing cooling fans, but they were not on.’
Manly disputes that adequate cooling and hydration measures were absent, stating the dojo’s rear doors were open, several floor-standing fans were available and enforced drink breaks were provided.
The club also said 10 staff members were present to monitor the 15 players taking part in the indoor session.
A 2024 coronial inquest found Titmuss died from exertional heat stroke after ‘most likely suffering involuntary dehydration’.
A pre-existing heart condition was found unlikely to have contributed to his death.
The Titmuss family claimed Manly failed Keith, saying he went to work and never returned home that day (Pictured, Keith’s father Paul Titmuss)
The inquest heard a paramedic recorded Titmuss’s body temperature at 41.9C, described as the ‘hottest they’d ever seen’, while his heart rate exceeded 140 beats per minute.
The coroner found the workout was ‘more likely than not inappropriate’.
Titmuss’s family alleges Manly failed to provide a safe system of work, properly assess his fitness, adequately hydrate players or provide a sufficiently cool training environment.
‘[Manly Warringah] owed a duty of care to the deceased as an employee and… breached the duty of care owed,’ the statement of claim said.
The family also claims Titmuss struggled physically during an outdoor sprint test three days before the fatal session, an allegation denied by Manly.
The Sea Eagles had introduced a heat policy after former prop Lloyd Perrett suffered an alleged heat stress-induced seizure during a training session in November 2017.
The policy reportedly identified the first four days of pre-season training as a period of increased heat-stress risk.
Perrett has also launched legal action against Manly, alleging he suffered exertional heat stroke, a seizure and psychiatric injury during the 2017 session. The club is defending that case.
The club said it had worked with the NRL to improve player protections against heat illness since the inquest
Sources familiar with the Titmuss proceedings have claimed the family previously received a payment of about $1million from the NRL and Manly’s insurer.
A Sea Eagles spokesperson said the club remained devastated by Titmuss’s death but could not address matters before the court.
‘The Manly Warringah Sea Eagles remain deeply saddened by the tragic passing of Keith Titmuss in November 2020,’ the spokesperson said.
‘Our thoughts continue to be with Keith’s family, friends and loved ones, who have endured an unimaginable loss.
‘During the coronial inquest, the club welcomed the opportunity to be involved and to take on board any and all potential learnings as highlighted during the proceedings.
‘Since then, the club has continued to work with the NRL to make improvements to the welfare and safety of players, particularly regarding heat illness policies and protocols.
‘Keith’s family are currently suing the club for damages in the NSW Supreme Court. It is not appropriate to comment on the matters that are the subject of those proceedings.
‘Our focus remains on acknowledging Keith’s memory and supporting those who continue to grieve his loss.’
Titmuss’s mother, Lafo, has previously described her son’s death as preventable and said the family wanted accountability.
‘We are just seeking justice. That’s why we’ve made the decision we’ve made,’ she said.
‘It’s a very hard thing because you have Manly, who acknowledged soon after the inquest that it should never happen again. It should never have happened in the first place.
‘[When it comes to] duty of care, [the] club absolutely failed our son. He went to work and never came home on that day.’
