If you argue that the 3 are not benefiting the OC (that is failing what is required under s. 37), you then can also allege that all 3 need to be removed because they breached s. 238 (2)(b). Specifically, argue that their united behaviour demonstrates a wholesale failure of diligence inasmuch as the 3 exhibit an inattentiveness to the needs of 50% of the owners.
You’d have to prove that their holding on to power is harming the building in some real and material way. Telling the Tribunal that it’s anti-democratic won’t cut the mustard. However, if they are using their power to benefit their lots to the exclusion of others or prevent maintenance that would be a different issue. The gang of three could just as easily say that they are keeping disruptive troublemakers away from the levers of power.