CHA licence suspension requires post-decisional hearing and a speaking order before continuation is decided.

Suspension of a CHA licence could not be finally sustained without minimal procedural fairness, because the affected licence-holder had to receive at least a post-decisional hearing and the Commissioner had to record reasons on whether the licence should continue. The earlier view that suspension could proceed without revocation was overtaken by the Larger Bench approach, which treated a personal hearing and a speaking order as necessary before the matter could be concluded. The appeal accordingly succeeded, and the Commissioner was directed to hear the CHA and decide the issue by a reasoned order.

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Issues: Whether the suspension of the CHA licence could be sustained without affording a personal hearing, and whether the Commissioner was required to pass a speaking order on the continuance of the licence.

Analysis: The earlier order had proceeded on the basis that the Commissioner could suspend the licence and not revoke it, but the subsequent Larger Bench view recognised that while a pre-decisional notice was not necessarily required for action under the relevant regulation, the affected party must at least be given minimal fairness by way of a post-decisional hearing. In light of that binding approach, the matter could not be finally concluded without hearing the CHA and recording reasons on the question whether the licence should continue.

Conclusion: The appeal succeeded, and the Commissioner was directed to grant a personal hearing and decide the matter by a speaking order.

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