Ridge v Baldwin
The rules of natural justice apply to administrative decisions affecting a person's rights, not only to judicial decisions: a landmark in the revival of judicial review.
Facts
Charles Ridge was the Chief Constable of Brighton. In 1958 he was charged with conspiracy to obstruct the course of justice, together with other police officers. He was acquitted, but the trial judge made critical comments about his leadership of the force. The Brighton Watch Committee, the police authority, then dismissed him without giving him notice of the charges or an opportunity to be heard. Its power to dismiss was conferred by the Municipal Corporations Act 1882. Mr Ridge challenged the dismissal, partly because it affected his pension rights.
Legal principle
The House of Lords held, by a majority, that the dismissal was void because the Watch Committee had failed to observe the rules of natural justice. Lord Reid rejected the view, which had grown up in earlier cases, that natural justice applied only to bodies with a duty to act judicially. The duty to act fairly applies whenever a body has power to make a decision affecting the rights of individuals, and in particular before dismissing an office holder who could only be removed for cause. Mr Ridge was entitled to know the charges against him and to be given an opportunity to answer them. The case revived the application of natural justice to administrative decisions.
Related cases on judicial review: procedural impropriety and legitimate expectations
- Cooper v Wandsworth Board of Works (1863) 14 CB NS 180
- Dimes v Proprietors of Grand Junction Canal (1852) 3 HLC 759
- Re Finucane's Application for Judicial Review [2019] UKSC 7
- Lloyd v McMahon [1987] AC 625
- McInnes v Onslow-Fane [1978] 1 WLR 1520
- Porter v Magill [2001] UKHL 67, [2002] 2 AC 357
- R (Bibi) v Newham London Borough Council [2001] EWCA Civ 607, [2002] 1 WLR 237
- R (Moseley) v Haringey London Borough Council [2014] UKSC 56, [2014] 1 WLR 3947
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