However, he died on 11 July 1935, 11 days after he formally became a Senator,[1] necessitating the appointment of Guy Arkins to replace him.

[1] Courtenay left school at the age of fourteen and began working as a messenger boy for J Tylor & Sons, a sanitary and hydraulic engineering firm.

He was later promoted to travelling salesman, eventually becoming general manager of the Australian division and securing an ownership stake.

[3] Outside of Tylors, Courtenay helped establish the NRMA in February 1920, serving as the inaugural treasurer but resigning within the year to protest staff reductions.

In 1920 he helped establish the Civic Reform Association to support non-Labor candidates in local government elections.

[3] Courtenay was elected to a Senate term beginning on 1 July 1935, polling the second-highest number of votes in New South Wales.

[5] John Cumpston, the director-general of health, accepted Courtenay's offer and directed that a post-mortem examination be performed to aid knowledge of metastatic cancer.