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PROJECT REPORT
ON

PRINCIPLES OF NATURAL
JUSTICE

SUBMITTED TO SUBMITTED BY
PROF. SUDERSHAN VERMA SMRITI SRIVASTAVA
LLM Ist SEMESTER
ROLL NO. – 2
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CONTENTS
1. INTRODUCTION…………………………………………………..3
2. ORIGIN……………………………………………………………..5
3. APPLICATION OF PRINCIPLES OF NATURAL JUSTICE……..6
4. WHEN CAN NATURAL JUSTICE BE CLAIMED……………….7
5. PRINCIPLES OF NATURAL JUSTICE………………………..….8
6. RULE AGAINST BIAS………………………………………..……9
• Types of bias………………………………………………..10
• Personal bias………………………………………………..10
• Pecuniary bias……………………………………………....10
• Subject matter bias……………………………………….....11
• Departmental bias…………………………………………...12
• Policy notion bias…………………………………………...12
7. AUDI ALTERAM PARTEM…………………………………….…13
• Notice…………………………………………………………13
• Hearing……………………………………………………..…14
➢ Right to cross examination……………………………..14
➢ Right to legal representative……………………………15
8. REASONED DECISION…………………………………………….16
9. CONCLUSION……………………………………………………….17
10.REFERENCES……………………………………………………….18
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INTRODUCTION
Principle of Natural Justice is derived from the word ‘Jus Natural’ of the Roman law and it is
closely related to Common law and moral principles but is not codified. It is a law of nature
which is not derived from any statute or constitution. The principle of natural justice is adhered
to by all the citizens of civilised State with Supreme importance. In the ancient days of fair
practice, at the time when industrial areas ruled with a harsh and rigid law to hire and fire, the
Supreme court gave its command with the passage of duration and establishment of social,
justice and economy statutory protection for the workmen.

Natural justice simply means to make a sensible and reasonable decision-making procedure on
a particular issue. Sometimes, it doesn’t matter what is the reasonable decision but, in the end,
what matters is the procedure and who all are engaged in taking the reasonable decision. It is
not restricted within the concept of ‘fairness’ it has different colours and shades which vary
from the context.

The concept and doctrine of Principles of Natural Justice and its application in Justice delivery
system is not new. It seems to be as old as the system of dispensation of justice itself. It has by
now assumed the importance of being, so to say, "an essential inbuilt component" of the
mechanism, through which decision-making process passes, in the matters touching the rights
and liberty of the people. It is no doubt, a procedural requirement but it ensures a strong
safeguard against any Judicial or administrative; order or action, adversely affecting the
substantive rights of the individuals. Natural justice is an expression of English common law,
and involves a procedural requirement of fairness. The principles of natural justice have great
significance in the study of Administrative law. It is also known has substantial justice or
fundamental justice or Universal justice or fair play in action. The principles of natural
justice are not embodied rules and are not codified. They are judge made rules
and are regarded has counterpart of the American procedural due process.

Basically, natural justice consists of 3 rules.

The first one is “Hearing rule” which states that the person or party who is affected by the
decision made by the panel of expert members should be given a fair opportunity to express
his point of view to defend himself.
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Secondly, “Bias rule” generally expresses that panel of expert should be biased free while
taking the decision. The decision should be given in a free and fair manner which can fulfil the
rule of natural justice.

And thirdly, “Reasoned Decision” which states that order, decision or judgement of the court
given by the Presiding authorities with a valid and reasonable ground.
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ORIGIN
Later on, the concept of natural justice was accepted by the English jurist. The word natural
justice is derived from the Roman word ‘jus-naturale’ and ‘lex-naturale’ which planned the
principles of natural justice, natural law and equity.

“Natural justice is a sense of what is wrong and what is right.”

'Natural Justice' is an expression of English common law. In one of the English decisions,
reported In Local Government Board v. Arlidge1, court observed, "...those whose duty it is to
decide must act Judicially. They must deal with the question referred to them without bias and
they must give to each of the parties the opportunity of adequately presenting the case made.
The decision must come to the spirit and with the sense of responsibility of a tribunal whose
duty it is to meet out justice."

In the United States of America, the expression 'natural justice' as such, is not so frequently
heard of since due process of law is guaranteed by the Constitution whenever an individual's
life, liberty or property is affected by State action. Though 'due process' is a vague and
undefined expression, the implications of which are not finally settled even today, but
observance of principles of natural Justice is secured by taking advantage of the phrase 'due
process'. In Snyder v. Massachusetts2, the Supreme Court of the United States observed that
there was a violation of due process whenever there was a breach of a "principle of Justice so
rooted in the traditions and conscience of our people as to be ranked as fundamental."

The principle of natural justice is a very old concept and it originated at an early age. The
people of Greek and roman were also familiar with this concept. In the days of Kautilya,
Arthashastra and Adam were acknowledged the concept of natural justice. According to the
Bible, in the case of Eve and Adam, when they ate the fruit of knowledge, they were forbidden
by the god. Before giving the sentence, eve was given a fair chance to defend himself and the
same process was followed in the case of Adam too.

In India, this concept was introduced at an early time. In the case of Mohinder Singh Gill vs.
Chief Election Commissioner3, the court held that the concept of fairness should be in every

1
(1915) AC 120 (138) HL
2
(1934) 291 US 97(105)
3
AIR 1978 SC 851
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action whether it is judicial, quasi-judicial, administrative and or quasi-administrative work. It

may be quoted as

“Indeed, natural justice is a pervasive facet of secular law where a spiritual touch enlivens
legislation, administration and adjudication, to make fairness a creed of life. It has many
colours and shades, many forms and shapes and, save where valid law excludes, it applies
when people are affected by acts of authority. It is the bone of healthy government, recognised
from earliest times and not a mystic testament of judge-made law. Indeed, from the legendary
days of Adam-and of Kautllya's Arthashastra-the rule of law has had this stamp of natural
justice, which makes it social justice. We need not go into these deeps for the present except to
indicate that the roots of natural justice and its foliage are noble and not new-fangled. Today
its application must be sustained by current legislation, case law or other extant principle, not
the hoary chords of legend and history. Our jurisprudence has sanctioned its prevalence even
like the Anglo-American system."

APPLICATION OF PRINCIPLES OF NATURAL JUSTICE

It is settled law and there is no dispute that the principles of natural justice are applicable to
judicial and quasi-judicial functions. But important question is that whether these principles
are applicable to administrative action.? Formerly Courts had taken the view that principles of
natural justice were inapplicable to administrative orders. In Franklin v. Minister of Town and
Country Planning4, Lord Tankertoon observed that as the duty imposed on the Minister was
merely administrative and not judicial or quasi-judicial the only question was, whether the
Minister has complied with the direction or not.

But as observed by Lord Denning in R v. Gaming Board5, at one time it was said that
principles of natural justice applied only judicial proceedings, but “that hereby was scotched”
in Ridge v. Baldwin6 and stated that principles of natural justice are applicable to “almost the
whole range of administrative powers”. Similarly in Breen v Amalgamated Engineering
Union7, Lord Denning said:

4
(1948) A.C. 87.
5
(1970) 2 AII ER 528
6
(1964) A.C. 40.
7
(1971) 1 AII EER 1148
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“It is now well settled that a statutory body, which is entrusted by statute, must act fairly. It
does not matter whether its functions are described as judicial or quasi judicial on one hand,
or as administrative on the other hand”

The same is position in India also. In State of Orissa v. (Dr) Binapani8 the Supreme Court
observed: “It is true that the order is administrative in character, but even an administrative
order which involves civil consequences…. must be made consistently with the rules of natural
justice

Again, in A.K Kraipak v. Union of India9, Hegde, J. observed:

“Till very recently it was opinion of the Courts that unless the authority concerned was required
by the law under which it functioned to act judicially, there was no rule for the application of
the rules of natural justice. The validity of that limitation is now is now questioned. If the
purpose of the rules of natural justice is to prevent miscarriage of justice one fails to see why
those rules should be made inapplicable to administrative inquiries.”

Similarly, in Maneka Gandhi v. Union of India10, Kailasam J. propounded:

“The Frontier between Judicial or Quasi-Judicial determination on the one hand an executive
on the other has become blurred. The rigid view that principles of natural justice applied only
to judicial and quasi-judicial acts and not to administrative acts no longer holds the fields.”

WHEN CAN NATURAL JUSTICE BE CLAIMED

Natural justice is an idealistic principle which is used for humanizing administrative action.
Whenever the courts insist in observance of the principles of natural justice, it means that they
take humanistic view if the issue required to be considered. The application of natural justice
to administrative action is based on the feeling that since the administration has acquired vast
powers to affect private rights without adequate safeguards, some protection to people’s rights
may be found in making bureaucracy follow due procedures in discharging its functions. Due
to this factor procedural fairness is regarded as an integral part of administration process. It is
felt that it is much more important to reach administrative decisions in the first stage rather

8
AIR 1967 SC 1269
9
AIR 1970 SC 150
10
AIR 1978 SC 597
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than to set aside bad decisions afterwards. herein lies the justification of natural justice as it
helps the administration reach good decisions.

Natural justice can be claimed when acting judicially or quasi-judicial like panchayat and
tribunals etc. as well. It includes the concept of fairness, basic moral principles and various
different kinds of biases and why the natural justice is required and what all special cases or
situation it includes where the principles of natural justice will not be applicable.

In the case of the Province of Bombay vs. Khushaldas Advani11, it was said that natural justice
will be applicable on statutory as it is a basic principle of Natural justice which leads to fairness
and justice.

PRINCIPLES OF NATURAL JUSTICE

Natural justice is not a fixed but flexible concept. The standards of natural justice vary with
situations. In Union of India v. P.K. Roy the Supreme Court held that the extent and application
of the doctrine of natural justice cannot be imprisoned within the strait jacket of a rigid formula.
The application of doctrine depends upon the nature of the jurisdiction conferred on the
administrative authority upon the character of the rights of the persons affected, the scheme
and policy of the statute and other relevant circumstances disclosed in particular case.

Natural justice represents higher procedural principles developed by judges which every
administrative agency must follow in taking decision adversely affecting the rights of private
individuals. The concept of natural justice entails three principles:

(1) Nemo judex in causa sua. – no man shall be Judge in his own cause or the deciding
authority must be impartial and without bias – Rule against Bias.
(2) Audi alteram partem – Hear the other side, or both sides must be heard, or no man
should be condemned unheard or that there must be fairness on the part of deciding
authority- Rule of hearing or fair hearing
(3) Reasoned Decision

11
AIR 1950 SC 222
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RULE AGAINST BIAS

Nemo Judex In Causa Sua - “No one should be a judge in his own case” because it leads
to rule of biases. Bias means an act which leads to unfair activity whether in a conscious or
unconscious stage in relation to the party or a particular case. Therefore, the necessity of this
rule is to make the judge impartial and given judgement on the basis of evidence recorded as
per the case.

Bias means an operative prejudice whether conscious or unconscious in relation to a party or

issue. Therefore, the ‘Rule Against Bais strikes against those factors which may improperly
influence a judge in arriving at a decision in any particular case. The requirement of this
principle is that the judge must be impartial and must decide the case objectively on the basis
of the evidence on record. Therefore, if a person, for whatever reason, cannot take an objective
decision on the basis of evidence on record he shall be said to be biased. A person cannot take
an objective decision in a case in which he/she has an interest for, as human psychology tells
us, very rarely can people take decisions against their own interests. This rule of
disqualification is applied not only to avoid the possibility of a partial decision but also to
ensure public confidence in the impartiality of the administrative adjudicatory process because
not only must “no man be judge in his/her own cause” but also “justice should not only be done
but should manifestly and undoubtedly be seen to be done”. Minimal requirement of natural
justice is that the authority must be composed of impartial persons acting fairly and without
prejudice and bias. A decision which is a result of bias is a nullity and the trial is “Coram non-
judice”. Inference of bias, therefore, can be drawn only on the basis of factual matrix and not
merely on the basis of insinuations, conjectures and surmises. Bias manifests variously and
may affect the decision in a variety of ways.

This principle is applicable not only to judicial proceedings but to quasi -judicial as well as
administrative proceedings.12. It is the minimal requirement of natural justice that the authority
must consist of impartial persons who are to act fairly and without prejudice and bias. A
decision which is a result of bias is a nullity and the trial is “coram non-judicie”13

12
J. Mohapatra and Co. v. State of Orissa, AIR 1984 SC 1572

13
Ranjit Thakur v. Union of India (1987) 4 SCC 611
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Type of Bias

1. Personal Bias.

2. Pecuniary Bias.

3. Subject matter Bias.

4. Departmental Bias.

5. Policy notion Bias.

6. Bias on the account of obstinacy.

Personal bias

Personal bias arises from a relation between the party and deciding authority. Which lead the
deciding authority in a doubtful situation to make an unfair activity and give judgement in
favour of his person. Such equations arise due to various forms of personal and professional
relations.

Relevant cases on this point is A.K. Kripak v. Union of India14, the Supreme Court quashed
the selections made by the selection board on the ground that one of the candidates appeared
before selection committee was also a member of the selection board.
Meenglass Tea Estate v. Their Workmen15 In this case, the manager of the factory conducted
inquiry against the workmen who were alleged to have assaulted him. The court disqualified
the manager on the ground of personal bias.

In State of U.P v. Mohd. Nooh 16 case a departmental inquiry was held against an employee
and one of the witnesses against the employee turned hostile. The inquiry officer then left the
inquiry and gave evidence against him and thereafter resumed to complete the inquiry and
passed the order of dismissal. The order of dismissal was quashed on the ground of personal
bias.

Pecuniary Bias

Pecuniary bias arises, when the adjudicator/ judge has monetary economic interest in the
subject matter of the dispute/ case. The judge, while deciding a case should not have any

14
AIR 1970 SC 150
15
AIR 1963 SC 1719
16
AIR 1958 SC 86
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pecuniary or economic interest. In other words, pecuniary interest in the subject matter of
litigation disqualifies a person from acting as a judge.

In Dr. Benham's case17, Dr. Benham was fined for practicing in the city of London without
license of the college of Physicians. According to the statute, the college is entitled to half of
the amount and the remaining goes to the King. Coke CJ. disallowed the claim (fine) on the
ground that the college had a pecuniary interest. (Fine against Dr. Benham was dismissed).

The rule of pecuniary bias was laid down in the case of Dimes v. D. J Canal18 a company filed
a suit against a landowner. Lord Chancellor (judge), who was a shareholder of the plaintiff
company heard the case and decided in favour of the company. On appeal, the House of Lords
quashed this decision on the ground that no man shall be judge of his own cause.

In R. v. Hendon Rural District Council, Ex parte charley19 case, one of the members of the
planning commission was an estate agent and he was acting for the applicant to whom
permission was granted by the planning commission. The decision of the planning commission
granting the permission was quashed on the ground of pecuniary bias.

Jeejeebhoy v. Asst. Collector20. In this case, it was found that one of the members of the bench
of the court was also a member of the co-operative society for which the disputed land had
been acquired. The bench was reconstituted.

Similarly, in Visakhapatnam Co-operative Motor Transport Ltd. v. G. Bangar Raju 21. case,
the district collector as the chairman of the regional transport authority granted motor permit
to the above co-operative society, to which he was also the president. The court set aside the
collector's action on the ground of pecuniary bias.

Subject Matter Bias

Those cases fall within this category where the deciding officer is directly, or otherwise,
involved in the subject matter of the case. Here again mere involvement would not vitiate the
administrative action unless there is a real likelihood of bias. Any interest or prejudice will
disqualify a judge from hearing the case. When the adjudicator or the judge has general interest
in the subject matter in dispute on account of his association with the administration or private

17
(1610) K8 Co. Rep. 11361
18
(1852) 3 HLC 579
19
(1933) 2 KB 606
20
AIR 1965 SC 455
21
AIR 1953 Mad
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body, he will be disqualified on the ground of bias if he has intimately identified himself with
the issues in dispute. To disqualify on the ground there must be intimate and direct connection
between the adjudicator and the issues in dispute. Now the question is, whether this principle
can be extended to administrative adjudication also. If so, no decision will be free from bias.
Gullampally Nageswara Rao v. A. P.S.R.T.C22 In this case, the government proposed
nationalization of motor transport. Objections for nationalization were referred to be heard by
the secretary to the Government, who upheld the validity of the scheme (for nationalization).
It was challenged on the ground that the said secretary in fact, initiated the nationalization.

Departmental Bias

The problem of ‘departmental bias’ is something which is inherent in the administrative

process, and if it is not effectively checked, it may negate the very concept of fairness in the
administrative proceeding. The problem of ‘departmental bias’ also arises in a different
context, when the functions of judge and prosecutor are combined in the same department. It
is not uncommon to find that the same department which initiates a matter also decides it,
therefore, at times departmental fraternity and loyalty militates against the concept of fair
hearing.

Policy notion bias

Issues arising out of preconceived policy notion is a very dedicated issue. The audience sitting
over there does not expect judges to sit with a blank sheet of paper and give a fair trial and
decision over the matter.

22
AIR 1959 SC 308
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AUDI ALTERAM PARTEM: RULE OF HEARING

It simply includes 3 Latin word which basically means that no person can be condemned or
punished by the court without having a fair opportunity of being heard. In a civilised society it
is assumed that a person against whom any action is sought to be taken, or whose right or
interest is being affected, shall be given a reasonable opportunity to defend himself.

In many jurisdictions, a bulk of cases are left undecided without giving a fair opportunity of
being heard. The literal meaning of this rule is that both parties should be given a fair chance
to present themselves with their relevant points and a fair trial should be conducted.

This is an important rule of natural justice and its pure form is not to penalize anyone without
any valid and reasonable ground. Prior notice should be given to a person so he can prepare to
know what all charges are framed against him. It is also known as a rule of fair hearing. The
components of fair hearing are not fixed or rigid in nature. It varies from case to case and
authority to authority.

Generally, the maxim includes two ingredients: (i) notice and (ii) hearing.

NOTICE

Valid and proper notice should be given to the required parties of the matter to further proceed
with the procedure of fair trial method. Even if the statute does not include the provision of
issue of notice, then it will be given prior to making decisions. This was held in the case of
Fazalbhai vs. custodian23.

In the case of Kanda vs. Government of Malaya24, the court held that notice must directly and
clearly specify on the matter of bias, facts and circumstances against which needs to be taken.
It’s one of the rights of the individual to defend himself so he should be familiar with the
relevant matter so he may contradict the statement and safeguard himself.

The notice should be with regard to the charges framed against the accused person and
proceeding to be held. He can only be punished on the charges which are mentioned in the
notice, not for any other charges.

23
AIR 1961 SC 284
24
1962 A.C. 322
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HEARING

The second requirement of Audi alteram partem maxim is that the party concerned must be
given an opportunity of being heard before any adverse action is taken against him.

The historic case of Ridge v. Baldwin25 has been rightly described as magna carta of natural
justice. In this case, a chief constable had been prosecuted but acquitted on certain charges of
conspiracy. While delivering the judgement certain remarks were made by the presiding judge
against the plaintiff’s character as a senior Police officer. Considering these remarks, the watch
committee dismissed the plaintiff from service.

The court of appeal decided that the watch committee was acting as an administrative authority
and was not exercising judicial or quasi-judicial power and therefore rules of natural justice
did not apply to the proceedings of dismissal. Reversing the decision of the Court of Appeal,
the House of Lords by majority of 4:1 held that the power of dismissal could not be exercised
without giving a reasonable opportunity of being heard and without observing the principles of
natural justice. The order of dismissal was therefore, not upheld.

In Maneka Gandhi v. Union of India,26 the passport was impounded by the government of
India ‘in public interest’. No opportunity was afforded to the petitioner before taking the
impugned action. The Supreme Court held that the order was violative of principles of natural
justice.

Right to present the case and evidence– After receiving the notice he must be given a reasonable
time period to prepare and present his case in a real and effective manner. The refusal should
not be done on the unreasonable ground or due to arbitrary.

Right to Cross Examination– Right of fair hearing includes the right to cross-examination
the statement made by the parties. If tribunals denied the right to cross-examination, then it
will violate the principles of natural justice. And all the necessary copies of documents should
be given and failure of that will also encroach the principle. The department should make
available officers who are involved in the procedure of investigating and do cross-examination.
Cross-examination is defined under Section 137 of the Indian Evidence Act, 1872.

25
(1964) AC 40.
26
AIR 1978 SC 597
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In certain exceptional cases, the right to cross-examination can be denied or rejected. Hari
Nath Mishra vs. Rajendra Medical College27, under this case a male student was charged off
some indecent behaviour towards a female student. So, here the right to cross-examination was
denied for the male student as it will lead to embracement for the female student and it will not
also lead to violation of natural justice.

Sometimes it becomes very necessary to keep the identity confidential as there is a threat of
life and property. And the same situation was faced in the case Gurubachan Singh vs. the
State of Bombay28. Let’s take an illustration, In the matter where lawyer and client are involved
so, nobody can force a lawyer to reveal what all information is given by the client to the lawyer
in relation to the case.

In the case of Ludhiana food product29, the court held that If the party itself refuse to cross-
examine the witness then it will not fall under miscarriage of natural justice.

Right of Legal representative– In the process of enquiry, every party has the right to have a
legal representative. Each party will be presented by the legally trained person and no one can
deny30. Similarly, the department has the same right to direct its officer even though there are
investigating officer in conducting an adjudicating proceeding.31

27
AIR 1975 SC 266
28
A.I.R. 1952 S.C. 221
29
1990 (47) ELT 294
30
A.K Roy v. Union of India AIR 1982 SC 710
31
Sanghi textile processor vs. Commissioner 1991 (55) ELT 151 A.P.
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REASONED DECISION
The third principle which has developed in course of time is that the order which is passed
affecting the rights of an individual must be a speaking order. This is necessary with a view to
exclude the possibility of arbitrariness in the action. A bald order requiring no reason to support
it may be passed in an arbitrary and irresponsible manner. It is tile reason for passing an order,
which checks the arbitrariness. It is a step-in furtherance of achieving the end where society is
governed by Rule of law.

The other aspect of the matter is that the party, against whom an order is passed, in fair play,
must know the reasons of passing the order. It has a right to know the reasons. In Maneka
Gandhi's case, it has been held that withholding of reasons for impounding the passport of the
petitioner was violative of the principles of natural justice. The orders against which appeals
are provided must be speaking orders. Otherwise, the aggrieved party is not in a position to
demonstrate before the appellate authority, as to in what manner, the order passed by the initial
authorities is bad or suffers from illegality. To a very great extent, in such matters bald orders
render the remedy of appeal nugatory.

However, it is true that administrative authorities or tribunals are not supposed to pass detailed
orders as passed by the courts of law. They may not be very detailed and lengthy orders but
they must at least show that the mind was applied and for the reasons, howsoever briefly they
may be stated, the order by which a party aggrieved is passed. There cannot be any prescribed
form in which the order may be passed but the minimum requirement as indicated above has
to be complied with. Our Supreme Court has many times taken the view that non-speaking
order amounts to depriving a party of a right 'of appeal. It has also been held in some of the
decisions that the appellate authority, while reversing the order must assign reasons for reversal
of the findings.
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CONCLUSION
The principles of natural justice have been adopted and followed by the judiciary to protect
public rights against the arbitrary decision by the administrative authority. One can easily see
that the rule of natural justice includes the concept of fairness: they stay alive and support to
safeguard the fair dealing.

So, at all the stages of the procedure if any authority is given off the judicial function is not
purely accepted but the main motive of the principal is to prevent the miscarriage of justice. It
is supreme to note that any decision or order which violates the natural justice will be declared
as null and void in nature, hence one must carry in mind that the principles of natural justice
are essential for any administrative settlement to be held valid.

As a matter of fact, the 7 principles of natural justice apply where there may not be any specific
provisions in the statute. These principles are inherent and natural in application requiring no
statutory provision for the same but the application of these principles can be excluded by
express provision under the law. For example, we have the provisions of Article 311 of the
Constitution of India where it is provided that before an officer is dismissed, removed or
reduced in rank, he must be afforded a reasonable opportunity of being heard in respect of the
charges levelled against him but at the same time it also provides that it may not be necessary
to afford that opportunity where for reasons recorded in writing it is found that it is reasonably
not practicable to hold an enquiry or where the President or the Governor has specified that in
the interest of security of the State it is not expedient to hold such enquiry To sum up, one finds
that Initially the principles of natural justice used to be applied to courts of law alone but later
on from judicial sphere it extended, to the tribunals exercising quasi-judicial functions and then
to the statutory authorities and the administrative authorities, who have upon them, the
responsibility of determining civil rights or obligations of the people. In normal conditions, an
action or a decision, judicial or administrative, affecting rights of an individual and resulting
in civil consequence is unthinkable. In the present day, without affording hearing by an
unbiased and impartial authority who must act objectively and must also give out his mind, as
to what weighed in decision making process, by incorporating reasons to support the decision
or, to say so, by giving a speaking order. This is necessary for a society, which is governed by
Rule of law. How substantive laws are applied and rights are determined is a question not less
important, to say it again, the principles of -natural justice are great humanising principles
intended to invest law with fairness to secure justice and to prevent miscarriage of justice.
 P a g e | 18

REFERENCES
BOOKS
1. Dr. Kailash Rai, Administrative Law (Allahabad Law Agency, Law
Publisher, Faridabad (Haryana)-121002,7th edn.,2011)
2. Dr. I.P Massey, Administrative law (Eastern Book Company,
Lucknow,8th edition., 2012)

INTERNET SOURCES
• www.blog.ipleaders.com
• www.legalservicesindia.com
• www.livelaw.in
• www.scconline.com