Ridge v Baldwin (1964)

Administrative Law · Exceptions to Natural Justice & Effect of Non-Compliance

Facts.

A Chief Constable (Ridge) was dismissed by the Watch Committee without being told the charges or given any hearing.

Issue.

Did natural justice apply to an administrative dismissal, and was the dismissal void for want of a hearing?

Held.

The House of Lords held the dismissal void. Natural justice is not confined to “judicial” bodies; it applies whenever a decision affects a person’s rights, and a decision made in breach of it is void.

Why it matters.

It swept away the artificial rule that natural justice applied only to “quasi-judicial” acts, reviving it as a general control — the case that made the modern law of fair hearing possible, and the intellectual parent of Kraipak and Maneka Gandhi in India.

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