In Re Nicholson and Haldimand-Norfolk Regional Board of Police Commissioners, Laskin, C.J.C., stated at page 324: In short I am of the opinion that although the appellant clearly cannot claim the procedural protections afforded to a constable with more than eighteen months’s service, he cannot be denied any protection. He should be treated ‘fairly’ not arbitrarily. I accept, therefore, for present purposes and as a common law principle what Megarry, J., accepted in Bates v. Lord Hailsham, at p. 1378, ‘that in the sphere of the so-called quasi-judicial the rules of natural justice run, and that in the administrative or executive field there is a general duty of fairness’.
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