Natural justice does not require a pre-hearing before further investigation under Competition law is directed.

No notice or pre-decisional hearing is required before the Competition Commission directs further investigation under Section 26(7), because the statutory scheme provides hearing only at later specified stages and the direction for further investigation is merely a continuation of the existing inquiry. Since that step does not itself create civil consequences or impair any legal right, natural justice is not attracted at that stage. The regulation on cross-examination applies to evidence before the Commission or Director General and does not confer a right to prevent further investigation.

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Issues: Whether the Competition Commission was required to give notice or hearing to the person against whom information was made or reference was received before directing further investigation under Section 26(7), and whether the absence of such hearing vitiated the order permitting cross-examination of witnesses by the informant.

Analysis: The statutory scheme under Section 26 shows that notice is expressly contemplated at the stage of forwarding the Director General's report and inviting objections in specified situations, but no similar requirement is provided before the Commission directs further investigation. The absence of express hearing rights at that stage is consistent with the earlier ruling that no notice is required before forming a prima facie opinion and directing investigation. A direction for further investigation is only a continuation of the earlier investigation and does not, by itself, visit the affected party with civil consequences or impair any legal right. The principles of natural justice therefore do not mandate a pre-decisional hearing at that stage. The Regulations permitting cross-examination operate in the context of evidence led before the Commission or the Director General and do not create a right to block further investigation before it is ordered.

Conclusion: No notice or hearing was required to be given to the petitioner before directing further investigation under Section 26(7), and the challenge to the order failed.

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