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 p. 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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