In Bates v. Lord Hailsham of St. Marylebone, [1972] 3 All E.R. 1019 (Ch.D.), the duty of fairness was extended to administrative tribunals. In that case Megarry J. stated at p. 1024: Let me accept 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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