Inherent jurisdiction to recall judgments affirms tribunals can correct proceedings tainted by procedural vitiation or jurisdictional defect.
The tribunal recognised its inherent jurisdiction to recall judgments distinct from review, holding that recall is available where procedural vitiation, fraud, lack of jurisdiction or failure of natural justice renders a proceeding a nullity. Drawing on the tribunal rules analogue to residual civil-procedure power and higher-court authority, the tribunal treated recall as an incidental order to prevent abuse of process and to correct proceedings affected by jurisdictional defect or gross procedural lapse.