''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 have a minimum set of employment rights, from Acts of Parliament, Regulations, common law and equity (legal concept), equity. ...
case heard by the
House of Lords
The House of Lords is the upper house of the Parliament of the United Kingdom. Like the lower house, the House of Commons of the United Kingdom, House of Commons, it meets in the Palace of Westminster in London, England. One of the oldest ext ...
.
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 conc ...
(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 t ...
.
Facts
The Brighton
police authority 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 (headed by George Baldwin) had acted unlawfully (''
ultra vires
('beyond the powers') is a Latin phrase used in law to describe an act that 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'') and the right to a fair hearing (''
audi alteram partem''). ''Ridge'' was the first time that the doctrine had been used to overturn a non-judicial (or
quasi-judicial
A quasi-judicial body is a non-judicial body which can interpret law. It is an entity such as an arbitration panel or tribunal board, which can be a public administrative agency (not part of the judicial branch of government) but also a contra ...
) 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
20th century in Brighton and Hove
United Kingdom constitutional case law