The following excerpt is from Bazant, Re; Bilson, University of Saskatchewan Faculty Association and Bazant v. University of Saskatchewan, 1984 CanLII 2421 (SK CA):
The requirement of procedural fairness first introduced in Canada in Nicholson is now firmly established in the law of Canada. Laskin, C.J.C., in Nicholson stated at page 680: “. . . I accept, therefore, for present purposes and as a common law principle what Megarry, J., accepted in Bates v. Lord Hailsham of St. Marylebone (1972), 1 W.L.R. 1373, 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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