''Ridge v Baldwin'' 964AC 40 was a

UK labour law United Kingdom labour law regulates the relations between workers, employers and trade unions. People at work in the UK can rely upon a minimum charter of employment rights, which are found in Acts of Parliament, Regulations, common law and equit ...

case heard by the

House of Lords The House of Lords, also known as the House of Peers, is the upper house of the Parliament of the United Kingdom. Membership is by appointment, heredity or official function. Like the House of Commons, it meets in the Palace of Westminste ...

. The decision extended the doctrine of

natural justice In English law, natural justice is technical terminology for the rule against bias (''nemo iudex in causa sua'') and the right to a fair hearing ('' audi alteram partem''). While the term ''natural justice'' is often retained as a general c ...

(procedural fairness in judicial hearings) into the realm of administrative decision making. As a result, the case has been described as "the landmark case" that opened up decisions taken by the UK executive to

judicial review in English law Judicial review is a part of UK constitutional law that enables people to challenge the exercise of power, usually by a public body. A person who contends that an exercise of power is unlawful may apply to the Administrative Court (a part of the ...

Facts

The Brighton

police authority A police authority in the United Kingdom is a public authority that is responsible for overseeing the operations of a police force. The nature and composition of police authorities has varied over time, and there are now just four dedicated "police ...

dismissed its Chief Constable (Charles Ridge) without offering him an opportunity to defend his actions. The Chief Constable appealed, arguing that the Brighton

Watch Committee In England and Wales, watch committees were the local government bodies which oversaw policing from 1835 until, in some areas, 1968. Establishment The Municipal Corporations Act 1835 required each borough to establish a "watch committee" and to ...

(headed by George Baldwin) had acted unlawfully (''

ultra vires ('beyond the powers') is a Latin phrase used in law to describe an act which requires legal authority but is done without it. Its opposite, an act done under proper authority, is ('within the powers'). Acts that are may equivalently be termed ...

'') in terminating his appointment in 1958 following criminal proceedings against him. Ridge also sought financial reparation from the police authority; having declined to seek reappointment, he sought a reinstatement of his pension, to which he would have been entitled with effect from 1960 had he not been dismissed, plus damages, or salary backdated to his dismissal.

Judgment

The House of Lords held that Baldwin's committee had violated the doctrine of natural justice, overturning the principle outlined by the Donoughmore Committee thirty years before that the doctrine of natural justice could not be applied to administrative decisions.

Significance

"Natural justice" is a legal doctrine which requires an absence of bias (''

nemo iudex in causa sua ''Nemo judex in causa sua'' (or ''nemo judex in sua causa'') (which, in Latin, literally means "no-one is judge in his own cause") is a principle of natural justice that no person can judge a case in which they have an interest. In many jurisdictio ...

'') and the right to a fair hearing (''

audi alteram partem (or ) is a Latin phrase meaning "listen to the other side", or "let the other side be heard as well". It is the principle that no person should be judged without a fair hearing in which each party is given the opportunity to respond to the evide ...

''). ''Ridge'' was the first time that the doctrine had been used to overturn a non-judicial (or

quasi-judicial A quasi-judicial body is non-judicial body which can interpret law. It is an entity such as an arbitration panel or tribunal board, that can be a public administrative agency but also a contract- or private law entity, which has been ...

) decision.

Notes

{{Use British English, date=September 2020 1963 in case law 1963 in British law House of Lords cases United Kingdom administrative case law United Kingdom labour case law History of Brighton and Hove United Kingdom constitutional case law