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The courtyard walls might not be visible from the street but are they visible from other units or areas of common property? If so, depending on the style of the units, it may or may not be reasonable for the OC to maintain uniformity.
Where I am, one unit has painted the internal face of courtyard walls, which are an extension of the townhouse walls. The particular brick appearance of those walls is one of the distinctive architectural features and I would not approve painting those walls.
Another resident wanted to cover their equivalent walls with timber panelling, and that was not approved.
Neither of the above examples are ‘visible from the street’ but they are visible from garden areas of common property used by other residents.