Natural justice requires notice and hearing before refusal to renew a municipal restaurant licence affecting livelihood.

Where continuation of a restaurant business depended on a municipal licence, refusal to renew the licence could not validly be made without prior notice and a fair opportunity of hearing. The SC held that such refusal carried civil and pecuniary consequences and affected livelihood, so the minimum requirements of natural justice applied before renewal was declined or the existing permission was cancelled. Because the Corporation gave no such opportunity before refusing renewal, the decision was void for breach of natural justice and liable to be quashed.

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Issues: Whether refusal to renew the restaurant licence, without prior notice and opportunity of hearing, was vitiated for breach of natural justice.

Analysis: The business of running a restaurant could not be carried on without a licence under the municipal law, and refusal to renew such a licence would necessarily entail civil and pecuniary consequences and affect livelihood. In that situation, before declining renewal or cancelling the existing permission, the minimum requirement of natural justice was notice and a fair opportunity to represent the case. The Corporation admittedly gave no such opportunity before taking the decision not to renew the licence, though the subsequent sealing of the premises clearly reflected that renewal had been refused.

Conclusion: The refusal to renew the licence was void for breach of the principles of natural justice and was liable to be quashed.

Ratio Decidendi: Where continuation of a business depends on a municipal licence, refusal to renew or cancellation of that licence cannot validly be made without prior notice and opportunity of hearing.

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