In summary, recent authority confirms that failure to provide a formal, oral hearing does not, in itself, constitute a denial of natural justice. Whether such a hearing is required will depend on the circumstances. Counsel for the petitioners did not attempt the difficult task of distinguishing the circumstances here present from those in Murphy v. Dowhaniuk. This was due to the additional obstacle, which he conceded to be insuperable, created by the fact that an oral hearing had not been requested.
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