Natural justice requires a hearing before review of rights-affecting orders; ex parte reconsideration is invalid.

An authority that reconsiders or reviews a decision affecting civil rights must afford the affected party a fair hearing, even if the governing rules do not expressly provide for review. The impugned review and reiteration orders were invalid because they were made without notice or opportunity of hearing, and the refusal to quash them on the ground that relief would be academic was unjustified since the orders could continue to operate unless set aside. The Court therefore quashed the later orders for breach of natural justice and restored the position before the review.

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Issues: Whether the order reviewing the earlier appellate order and reducing the appellant to subsistence allowance only could stand when it was made without giving the appellant an opportunity of hearing, and whether the High Court was justified in refusing relief on the footing that quashing the review order would be academic.

Analysis: The appellant's grievance was directed specifically against the later orders of review and reiteration, not against the original reinstatement order. The reconsideration directly affected his rights and was therefore required to be made in accordance with fair procedure. Even where the rules did not expressly provide for review, an authority deciding a controversy affecting rival rights must observe the basic requirement of hearing the affected party. The refusal to grant relief merely because the original order was said to be invalid under another view of the rules was unjust, since the impugned review orders might continue to be treated as operative unless set aside. The Court also noted that the rules contemplated hearing in appellate proceedings and reflected the principle of natural justice.

Conclusion: The review order dated 25 February 1961 and the subsequent order dated 18 January 1964 were invalid for breach of natural justice, and the High Court ought to have quashed them.

Final Conclusion: The appellant succeeded and the matter was sent back to the position prior to the impugned review, with the appellant entitled to costs.

Ratio Decidendi: Where an authority reconsiders or reviews a decision affecting civil rights, a fair opportunity of hearing must be afforded to the affected party, and an order made in breach of that requirement is liable to be set aside even if the governing rules are silent on review.

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