''Ridge v Baldwin''

964 Year 964 ( CMLXIV) was a leap year starting on Friday (link will display the full calendar) of the Julian calendar. Events Byzantine Empire * Arab–Byzantine War: Emperor Nikephoros II continues the reconquest of south-eastern Anatoli ...

AC 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 Westminster ...

. The decision extended the doctrine of natural justice (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 th ...

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 "polic ...

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 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 terme ...

'') 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 Donoughmore (spelt ''Donaghmore'' by Ordnance Survey Ireland; Irish: ''Domhnach Mór'') is a civil and Catholic parish in County Cork, Ireland. This rural district lies 25 km west-northwest of Cork city. Donoughmore is part of the Cork Nort ...

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 jurisdicti ...

'') 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) 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