1. Andrew Clement Sovh
Wimbledon, London, England, United Kingdom & Sants-Montjuïc, Barcelona,
Catalonia
N/A
candrewsovh@gmail.com - +85290844032
Dear Sir/Madam,
Hello. I saw your advertisement and I think I will fit you just perfectly. I pride myself significantly with my pristine
and consummate efficiency. A cheerful disposition, archetypal can-do attitude and exemplary interpersonal
ability make me a strong candidate for the advertised position. My sharp industry exposure will certainly add
profound value to your firm.
I am a licensed barrister in England. I am happy to assist on matters about criminal law, civil law, administrative
law, EU law, contract law, immigration law, arbitration et cetera. I have actual experiences in US law through
a few cases I have done.
This could be an outstanding opportunity for me.
I look forward to hearing from you soon to further my acumen and aspirations.
Yours faithfully,
Andrew Clement Sovh
Authorized to work in the US for any employer
WORK EXPERIENCE
Government Advocacy per request
Crown Prosecution Service, Her Majesty's Government(U.K.) - September 2015 to Present
Responsibilities
To represent HM's Government upon request
EDUCATION
Legum Baccalaureus in Legum Baccalaureus
Birkbeck College, University of London, England, U.K. - London
2012 to 2015
TEFL(Teaching English as a foreign language) in Teaching English as a foreign
language
Trinity College London - London
2014 to 2014
Medical Humanities Postgraduate Diploma in Medical Humanities
Birkbeck College, University of London, England, U.K. - London
2012 to 2014
2. SKILLS
International Law(Common Law) (4 years), Criminal Law(Common Law) (4 years), Civil Law Systems (4
years), Chinese(Cantonese & Taiwanese) (10+ years), Immigration Law(Common Law) (4 years), Contract
Law (4 years), Administrative Law(Common Law) (4 years), French(allons-y parlons francais avec moi
un deux trois c'est parti je vous comprends parfaitement) (10+ years), Common Law Systems (4 years),
Differences between Civil Law Systems & Common Law systems (4 years), Civil Law(Common Law) (4
years), Equity (law) (Common Law) (4 years), Arbitration (4 years), Trial Advocacy (Common Law) (4 years),
Laws of the U.S.A. (4 years), Equity (law) in the United States (4 years), Jurist (4 years), Administration of
Justice (4 years), Tort (4 years), Evidence (4 years), Police Station Representation(United Kingdom) (Less
than 1 year), Court Bail Applications(United Kingdom) (Less than 1 year)
CERTIFICATIONS
Legum Baccalaureus
TEFL(Teaching English as a foreign language)
Medical Humanities Postgraduate Diploma
PUBLICATIONS
translating from English to Chinese(Traditional) Chitosan A Natural Solution for Wound
Healing published on the Jan 2014 issue of Journal Commnity Nursing(UK) by Prof.
Jackie Stephen-Haynes, Elaine Gibson & Michelle Greenwood
November 2015
殼聚醣:一個自然解決傷口癒合的方案(Chitosan A Natural Solution for Wound Healing)
TRANSLATED BY MR. ANDREW CLEMENT SOVH(MYSELF)
written by Jackie Stephen-Haynes(Professor and Consultant Nurse, Practice Development Unit, Birmingham
City University and Worcestershire Health and Care Trust), Elaine Gibson, Michelle Greenwood(Consultant
Nurse Tissue Viability, Walsall Healthcare NHS Trust and Associate Lecturer, Practice Development Unit,
Birmingham City University) published on the Jan 2014 issue of Journal of Community Nursing(UK)
殼聚醣是高級傷口護理敷料擁有吸收和保留水分性能和抗菌性能.
殼聚醣在傷口護理領域提供了一個新的多功能的及生物互動的蛋白酶調節劑.
利用自然資源變得越來越重要, 人口老齡化不可避免地增加跨急診室和社區的傷口的患病率, 預防和管理感染
仍是優先事項, 這些因素指出需要這敷料.
本文審議支持殼聚醣的文獻和使用護理研究示例說明對病人的影響.
關鍵詞：
1高級傷口護理2天然來源3傷口癒合和膠凝能力
傷口護理最近幾年在科學,技術和實體證據方面進步神速.
更先進，更具有高吸收能力和更具有保濕能力的敷料變得更廣泛應用(例如:藻酸鹽,泡沫,超吸收劑等等)
(Jones和 Barraud, 2013年).
4. R先生的皮膚撕裂被組織存活護士分類為第3類（斯蒂芬-海恩斯，2012年）。他是一個已知有胰島素依賴型糖
尿病, 有神經病變,有高血壓和有高葡萄糖的病人，並有靜脈腿部潰瘍和蜂窩組織炎的歷史。
經急症室初步評估R先生被轉介到組織存活服務作諮詢和管理。
組織存活的團隊發現R先生皮膚撕裂長8.2厘米寬2.2厘米(圖4) 。
組織存活團隊全面評估R先生的皮膚撕裂後組織存活團隊決定管理滲出物，止血和抗菌（圖5）。
10天後傷口完全癒合。
病例報告1討論
糖尿病患者的傷口的風險是充分證明的。特別是，那些患者的傷口，如果沒有適當地進行管理，可能出現並發
症（Lioupis，2005年）。重要的是，預防，適當的評估和管理維護可以防止R先生的皮膚撕裂惡化成一個腿
部潰瘍（湯普森 - 麥克海爾，2013年）。儘管他的高潛在風險，R先生的10天傷口癒合時間內没有抗生素被使
用。
病例報告2
一位60多歲的病人聖誕節期間撲殺火雞創傷到他的無名指造成末節指骨損傷，（圖7和圖8）初步急救治療包
括貼膠布，但無法止血, 當地醫生他到了組織存活團隊組織存活的團隊決定應用殼聚醣到病人傷口床作止血和
減少感染。
這種做法維護了他的手功能的同時提供保護從而使他能夠繼續工作。
病例報告2討論
維持日常生活活動能力，並能夠繼續工作是為這名患者是必不可少的。滲出物的管理，傷口周圍的保護，減少
感染的風險，同時保持充分的功能和靈巧是首要關心的問題。
病例報告1和病例報告2結論
殼聚醣是一種蟹殼中提取天然多醣。殼聚醣無毒性，無刺激良好的生物兼容性。由於其高吸收和保濕性，殼聚
醣可吸收過量的滲出物，保持濕潤環境傷口癒合，加速傷口癒合，促進肌膚再生。殼聚醣促進患者的舒適度和
緩解疼痛。
figures 4, 5, 7 & 8 are sadly not able to appear in the system(s) concerned
要點
1保持濕潤的傷口癒合環境，預防和控制感染是必不可少的.
2醫護人員需要選擇病人接受的產品.
3殼聚醣是從天然來源的傷口敷料.
感謝
Coulter A, Collins A (2011) Making shared decision-making a reality: No decision about me without me. King’s
Fund,
London. Available online at: www.kingsfund.org.uk/document.rm?id=9190
Cutting K, White R (2005) Criteria for identifying wound infection. Ostomy Wound Manage 51(1): 28–34
Dai T, Tanaka M, Huang YY, Hamblin R (2011) Chitosan preparations for wounds and burns: antimicrobial
and wound-
healing effects. Expert Rev Anti Infect Ther 9(7): 857–79
Her Majesty’s Department of Health (2009) Transforming Community Services: Ambition, Action,
Achvement. Transforming services for acute care closer to home. Available online at: http://ww.dh.gov.uk/
prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_102198.pdf
Her Majesty’s Department of Health (2010a) Equity and Excellence: Liberating the NHS. DH, London. Available
online at: www.
dh.gov.uk/prod_consum_dh/groups/dh_
5. digitalassets/@dh/@en/@ps/documents/
digitalasset/dh_118610.pdf
Her Majesty’s Department of Health (2010b) QIPP: Quality, Innovation, Productivity and Prevention. DH,
London. Available online at: www.dh.gov.uk/en/Healthcare/
Qualityandproductivity/index.ht
Her Majesty’s Department of Health (2011) Innovation, Health and ealth: accelerating adotion and diffusion in
thNHS. DH, London. Available online at:http://ww.dh.
gov.uk/prod_consum_dh/groups/
dh_digitalassets/documents/digitalasset/
dh_134597.pdf
Dowsett C (2008) Exudate management: a patient-centred approach. J Wound Care 17(6): 249–52
European Wound Management Association (2013) Antimicrobials and non-healing wounds: Evidence,
controversies and suggestions.
J Wound Care 22(suppl 5): S1–S89. Available online at: http://ewma.
org/fileadmin/user_upload/EWMA/pdf/
EWMA_Projects/Antimicrobial/JWC_
EWMA_supplement_NO_CROPS.pdf
Foda NH, El-laithy HM, Tadros MI (2007) Implantable biodegradable sponges: effect of interpolymer complex
formation of chitosan with gelatin on the release behavior of tramadol hydrochloride. Drug Dev Ind Pharm 33(1):
7–17 International Consensus. Optimising Wellbeing in people living with a wound. An expert working group
review. London: Wounds International, 2012. vailable online at: http://ww. woundsinternational.om Jayakumar
R, Prabaharan M, Sudheesh Kumar PT, Nair SV, et al (2011) Biomaterials based on chitin and chitosan
in wound dressing applications. Biotechnol Adv 29: 322–337 Jones J, Barraud J (2013) Superabsorbent
dressings — have we reached maximum capacity? J Community Nurs 27(4): 66–72 Khor E, Lim LY (2003)
Implantable applications of chitin and chitosan. Biomaterials 24(13): 2339–49 Lee DW, Lim H, Chong HN,
Shim WS (2009) Advances in chitosan material and its hybrid derivatives: a review. Open Biomaterial J 1: 10–
20 Li Q, Dunn ET, Grandmaison EW, Goosen MFA (1992) Applications and properties of chitosan. J Bioact
Compat Polym 7: 370–97 Lioupis C,(2005) Effects of diabetes mellitus on wound healing: an update. J Wound
Care 14(2): 84–6 Lu G, Ling K, Zhao P, et al (2010) A novel in situ-formed hydrogel wound dressing by the
photocross-linking of a chitosan derivative. Wound Rep Regen 18: 70–9 Mezzana P (2008) Clinical efficacy
of a new chitin nanofibrils-based gel in w ound healing. Acta Chir Plast 50(3):81–4 Niekraszewicz A (2005)
Chitosan medical dressings. Fibres and Textiles in Eastern Europe 13, 6(54): 16–18 Ousey K, Stephenson
J, Barrett S, et al (2013) Wound care in five English NHS Trusts: results of a survey. Wounds UK 9(4): 20–
8 Payne RL, Martin ML (1993) Defining and classifying skin tears: need for a common language. Ostomy
Wound Manage 39(5): 16–26 Stephen-Haynes J (2012) Skin tears: achieving positive clinical and financial
outcomes. Br J Community Nurs 17(Sup 1): S6–S16 Stephen-Haynes J, Bielby A, Searle R (2011) Putting
patients first: Reducing the human and economic costs of wounds through the appropriate use of advanced
wound management products. Wounds UK 7(3): 47–55 Thompson-McHale S (2013) Skin tears: assessment,
prevention,classification and management. Nurs Residential Care 15(11): 710–14 Wounds UK (2013) Best
Practice Statement. The use of topical antimicrobial agents in wound management. 3rd edn. Wounds UK,
London
ROMANTIC ECONOMY
2015
A BOOK WRITTEN BY MYSELF
Blurring Differences Between The Common Law Systems & Civil Law Systems
August 2015
Benignly be noted that the following is only part of the full writing published.
6. The contrast between the civil law and the common law legal systems has become increasingly blurred with
the growing paramount importance of jurisprudence(similar to case law but not binding) in civil law countries
and the growing importance of statute law and codes in common law countries.
One exemplary exampe is the U.S.A.. The United States of America is a common law nation(apart from
Louisiana). Since 1812 U.S. courts have held that criminal law must be embodied in statute if the public is to
have fair notice, commercial law(the Uniform Commercial Code in the early 1960s) and procedure(the Federal
Rules of Civil Procedure in the 1930s and the Federal Rules of Evidence in the 1970s).
But be noted that in each case, the statute sets the general principles, but the interstitial common law process
determines the scope and application of the statute.
Another
Contrasts between common law and civil law systems
Constant jurisprudence
In common law systems, a single decided case is binding common law (connotation 1), under the principle
of stare decisis. In contrast, in civil law systems, case law only acquires weight when a long series of cases
use consistent reasoning, called jurisprudence constante. In civil law systems, individual decisions have only
advisory, not binding effect.
General principles of law
Both common law and civil law jurisdictions have formed what they variously call "pure common law" or "general
principles of law" to define what the law is in the absence of, or gap in, legislation. In common law systems,
judge made law is binding to the same extent as statute or regulation. In civil law systems, case law is advisory,
not binding. Civil law lawyers consult case law to obtain their best prediction of how a court will rule, but
comparatively, civil law judges are less bound to follow it.
Adversarial system vs. inquisitorial system
Common law systems tend to give more weight to separation of powers between the judicial branch (which
promulgates common law (connotation 1)) and the executive branch (which promulgates regulatory law, called
"administrative law" in civil law systems). In contrast, civil law systems often allow individual officials to exercise
both powers.
Common law courts usually use an adversarial system, in which two sides present their cases to a neutral
judge. In contrast, civil law systems usually use an inquisitorial system in which an examining magistrate serves
two roles by developing the evidence and arguments for one side and then the other during the investigation
phase.
The examining magistrate then presents the dossier detailing his or her findings to the president of the bench
that will adjudicate on the case where it has been decided that a trial shall be conducted. Therefore, the
president of the bench's view of the case is not neutral and may be biased while conducting the trial after
the reading of the dossier. Unlike the common law proceedings, the president of the bench in the inquisitorial
system is not merely an umpire and is entitled to directly interview the witnesses or express comments during
the trial, as long as he or she does not express his or her view on the guilt of the accused.
The proceeding in the inquisitorial system is essentially by writing. Most of the witnesses would have given
evidence in the investigation phase and such evidence will be contained in the dossier under the form of police
reports. In the same way, the accused would have already put his or her case at the investigation phase but he
7. or she will be free to change her or his evidence at trial. Whether the accused pleads guilty or not, a trial will be
conducted. Unlike the adversarial system, the conviction and sentence to be served (if any) will be released
by the trial jury together with the president of the trial bench, following their common deliberation.
There are many exceptions in both directions. For example, most proceedings before U.S. federal and state
agencies are inquisitorial in nature, at least the initial stages (e.g., a patent examiner, a social security hearing
officer, and so on), even though the law to be applied is developed through common law processes.
Contrasting role of treatises and academic writings in common law and civil law systems
The role of the legal academy presents a significant "cultural" difference between common law (connotation
2) and civil law jurisdictions.
In common law jurisdictions, legal treatises compile common law decisions and state overarching principles
that (in the author's opinion) explain the results of the cases. However, in common law jurisdictions, treatises
are not the law, and lawyers and judges tend to use these treatises as only "finding aids" to locate the relevant
cases. In common law jurisdictions, scholarly work is seldom cited as authority for what the law is. When
common law courts rely on scholarly work, it is almost always only for factual findings, policy justification, or
the history and evolution of the law, but the court's legal conclusion is reached through analysis of relevant
statutes and common law, seldom scholarly commentary.
In contrast, in civil law jurisdictions, courts give the writings of law professors significant weight, partly because
civil law decisions traditionally were very brief, sometimes no more than a paragraph stating who wins and
who loses. The rationale had to come from somewhere else: the academy often filled that role. This balance
may shift as civil law court decisions move in the direction of common law reasoning
Equity (law) in the United States of America
(for example, In modern practice, perhaps the most important distinction between law and equity is the set of
remedies each offers. The most common civil remedy a court of law can award is monetary damages. Equity,
however, enters injunctions or decrees directing someone either to act or to forbear from acting. Often, this form
of relief is in practical terms more valuable to a litigant; for example, a plaintiff whose neighbor will not return his
only milk cow, which had wandered onto the neighbor's property, may want that particular cow back, not just
its monetary value. However, in general, a litigant cannot obtain equitable relief unless there is "no adequate
remedy at law"; that is, a court will not grant an injunction unless monetary damages are an insufficient remedy
for the injury in question. Law courts can also enter certain types of immediately enforceable orders, called
"writs" (such as a writ of habeas corpus), but they are less flexible and less easily obtained than an injunction.
Another distinction is the unavailability of a jury in equity: the judge is the trier of fact. In the American legal
system, the right of jury trial in civil cases tried in federal court is guaranteed by the Seventh Amendment in
Suits at common law, cases that traditionally would have been handled by the law courts. The question of
whether a case should be determined by a jury depends largely on the type of relief the plaintiff requests. If a
plaintiff requests damages in the form of money or certain other forms of relief, such as the return of a specific
item of property, the remedy is considered legal, and a jury is available as the fact-finder. On the other hand,
if the plaintiff requests an injunction, declaratory judgment, specific performance, modification of contract, or
some other non-monetary relief, the claim would usually be one in equity.
Thomas Jefferson explained in 1785 that there are three main limitations on the power of a court of equity: "If
the legislature means to enact an injustice, however palpable, the court of Chancery is not the body with whom
a correcting power is lodged. That it shall not interpose in any case which does not come within a general
description and admit of redress by a general and practicable rule." The US Supreme Court, however, has
concluded that courts have wide discretion to fashion relief in cases of equity. The first major statement of this
8. power came in Willard v. Tayloe, 75 U.S. 557 (1869). The Court concluded that "relief is not a matter of absolute
right to either party; it is a matter resting in the discretion of the court, to be exercised upon a consideration
of all the circumstances of each particular case." Willard v. Tayloe was for many years the leading case in
contract law regarding intent and enforcement. as well as equity.
In the United States today, the federal courts and most state courts have merged law and equity in the courts
of general jurisdiction, such as county courts. However, the substantive distinction between law and equity
has retained its old vitality. This difference is not a mere technicality, because the successful handling of
certain law cases is difficult or impossible unless a temporary restraining order (TRO) or preliminary injunction
is issued at the outset, to restrain someone from fleeing the jurisdiction taking the only property available to
satisfy a judgment, for instance. Furthermore, certain statutes like Employee Retirement Income Security Act
specifically authorize only equitable relief, which forces US courts to analyze in lengthy detail whether the relief
demanded in particular cases brought under those statutes would have been available in equity.
Equity courts were widely distrusted in the northeastern US following the American Revolution. A serious
movement for merger of law and equity began in the states in the mid-19th century, when David Dudley Field II
convinced New York State to adopt what became known as the Field Code of 1848. The federal courts did not
abandon the old law/equity separation until the promulgation of the Federal Rules of Civil Procedure in 1938.
Today three states still have separate courts for law and equity; the most notable is Delaware, whose Court
of Chancery is where most cases involving Delaware corporations are decided. However, merger in some
states is less than complete; some other states (such as Illinois and New Jersey) have separate divisions for
legal and equitable matters in a single court. Besides corporate law, which developed out of the law of trusts,
areas traditionally handled by chancery courts included wills and probate, adoptions and guardianships, and
marriage and divorce. Bankruptcy was also historically considered an equitable matter; although bankruptcy in
the United States is today a purely federal matter, reserved entirely to the United States Bankruptcy Courts by
the enactment of the United States Bankruptcy Code in 1978, bankruptcy courts are still officially considered
"courts of equity" and exercise equitable powers under Section 105 of the Bankruptcy Code.
After US courts merged law and equity, American law courts adopted many of the procedures of equity courts.
The procedures in a court of equity were much more flexible than the courts at common law. In American
practice, certain devices such as joinder, counterclaim, cross-claim and interpleader originated in the courts
of equity. Also, the modern class action evolved out of the equitable doctrine of virtual representation, which
enabled a court of equity to fully dispose of an estate even though it might contain contingent interests held
by persons over which the court did not have direct jurisdiction.
Thanks to
Letter from Thomas Jefferson to Phillip Mazzei, November 1785.
Willard v. Tayloe, 75 U.S. 557, 565.
John P. Dawson, "Judicial Revision of Frustrated Contracts: The United States." Boston University Law
Review. 64:1 (January 1984), p. 32.
"Events Subsequent to the Contract As a Defence to Specific Performance," Columbia Law Review, May 1916,
p. 411.
Shirley Renner, Inflation and the Enforcement of Contracts. Cheltenham, England: Elgar, 1999, p. 20.
See, e.g., Sereboff v. Mid Atlantic Medical Services, Inc., No. 05–260, slip op. (U.S. May 15, 2006) (Roberts,
C.J. for a unanimous court) (reviewing the scope of equitable relief as authorized by the ERISA statute).
Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002).
Douglas Laycock, Modern American Remedies, 3d ed. (Aspen Press 2002), page 370.
9. The other two are Mississippi and Tennessee. Sources that mention four states (i.e., Laycock 2002) generally
include Arkansas, which abolished its separate chancery courts as of January 1, 2002.[1]
Hawes, Lesley Anne (January–February 2013). "Another Conflict in the Circuits Brewing Over Bankruptcy
Court’s Equitable Powers Under §105(a)". ABF Journal. Retrieved 18 June 2015.
nemo iudex in causa sua & audi alteram partem
In English law, natural justice is technical terminology for the rule against bias (nemo iudex in causa sua) and
the right to a fair hearing (audi alteram partem). While the term natural justice is often retained as a general
concept, it has largely been replaced and extended by the general "duty to act fairly".
The basis for the rule against bias is the need to maintain public confidence in the legal system. Bias can take
the form of actual bias, imputed bias or apparent bias. Actual bias is very difficult to prove in practice while
imputed bias, once shown, will result in a decision being void without the need for any investigation into the
likelihood or suspicion of bias. Cases from different jurisdictions currently apply two tests for apparent bias:
the "reasonable suspicion of bias" test and the "real likelihood of bias" test. One view that has been taken is
that the differences between these two tests are largely semantic and that they operate similarly.
The right to a fair hearing requires that individuals should not be penalized by decisions affecting their rights or
legitimate expectations unless they have been given prior notice of the case, a fair opportunity to answer it, and
the opportunity to present their own case. The mere fact that a decision affects rights or interests is sufficient
to subject the decision to the procedures required by natural justice. In Europe, the right to a fair hearing is
guaranteed by Article 6(1) of the European Convention on Human Rights, which is said to complement the
common law rather than replace it.
Rule against bias
-In general
A person is barred from deciding any case in which he or she may be, or may fairly be suspected to be, biased.
This principle embodies the basic concept of impartiality and applies to courts of law, tribunals, arbitrators
and all those having the duty to act judicially. A public authority has a duty to act judicially whenever it makes
decisions that affect people's rights or interests, and not only when it applies some judicial-type procedure in
arriving at decisions.
The basis on which impartiality operates is the need to maintain public confidence in the legal system. The
erosion of public confidence undermines the nobility of the legal system, and leads to ensuing chaos. The
essence of the need for impartiality was observed by Lord Denning, the Master of the Rolls, in Metropolitan
Properties Co. (F.G.C.) Ltd. v. Lannon (1968): "Justice must be rooted in confidence and confidence is
destroyed when right-minded people go away thinking: 'The judge was biased.'"
Public confidence as the basis for the rule against bias is also embodied in the often-quoted words of Lord
Hewart, the Lord Chief Justice of England and Wales, that "[i]t is not merely of some importance, but of
fundamental importance that justice should not only be done, but should manifestly be seen to be done".
-Forms of bias
1Actual and imputed bias
A portrait of the Lord Chancellor, Lord Cottenham (Charles Pepys, 1st Earl of Cottenham, 1781–1851), by
Charles Robert Leslie. In Dimes v. Grand Junction Canal Proprietors (1852), his Lordship was disqualified
from hearing a case as he had a pecuniary interest in the outcome.
10. Bias may be actual, imputed or apparent. Actual bias is established where it is actually established that a
decision-maker was prejudiced in favour of or against a party. However, in practice, the making of such an
allegation is rare as it is very hard to prove.
One form of imputed bias is based on the decision-maker being a party to a suit, or having a pecuniary or
proprietary interest in the outcome of the decision. Once this fact has been established, the bias is irrebuttable
and disqualification is automatic – the decision-maker will be barred from adjudicating the matter without the
need for any investigation into the likelihood or suspicion of bias. A classic case is Dimes v. Grand Junction
Canal Proprietors (1852), which involved an action between Dimes, a local landowner, and the proprietors of
the Grand Junction Canal, in which the Lord Chancellor, Lord Cottenham, had affirmed decrees made to the
proprietors. However, it was discovered by Dimes that Lord Cottenham in fact owned several pounds worth
of shares in the Grand Junction Canal. This eventually led to the judge being disqualified from deciding the
case. There was no inquiry as to whether a reasonable person would consider Lord Cottenham to be biased,
or as to the circumstances which led Lord Cottenham to hear the case.
In certain limited situations, bias can also be imputed when the decision-maker's interest in the decision is
not pecuniary but personal. This was established in the unprecedented case of R. v. Bow Street Metropolitan
Stipendiary Magistrate, ex parte Pinochet Ugarte (No. 2) (1999). In an appeal to the House of Lords, the Crown
Prosecution Service sought to overturn a quashing order made by the Divisional Court regarding extradition
warrants made against the ex-Chilean dictator, Senator Augusto Pinochet. Amnesty International (AI) was
given leave to intervene in the proceedings. However, one of the judges of the case, Lord Hoffmann, was
a director and chairperson of Amnesty International Charity Ltd. (AICL), a company under the control of AI.
He was eventually disqualified from the case and the outcome of the proceedings set aside. The House of
Lords held that the close connection between AICL and AI presented Lord Hoffmann with an interest in the
outcome of the litigation. Even though it was non-pecuniary, the Law Lords took the view that the interest was
sufficient to warrant Lord Hoffmann's automatic disqualification from hearing the case. In Locabail (U.K.) Ltd.
v. Bayfield Properties Ltd. (1999), the Court of Appeal warned against any further extension of the automatic
disqualification rule, "unless plainly required to give effect to the important underlying principles upon which
the rule is based".
2Apparent bias
Apparent bias is present where a judge or other decision-maker is not a party to a matter and does not have
an interest in its outcome, but through his or her conduct or behaviour gives rise to a suspicion that he or she
is not impartial. An issue that has arisen is the degree of suspicion which would provide the grounds on which
a decision should be set aside for apparent bias. Currently, cases from various jurisdictions apply two different
tests: "real likelihood of bias" and "reasonable suspicion of bias".
The real likelihood test centres on whether the facts, as assessed by the court, give rise to a real likelihood
of bias. In R. v. Gough (1993), the House of Lords chose to state the test in terms of a "real danger of bias",
and emphasized that the test was concerned with the possibility, not probability, of bias. Lord Goff of Chievely
also stated that "the court should look at the matter through the eyes of a reasonable man, because the court
in cases such as these personifies the reasonable man". However, the test in Gough has been disapproved
of in some Commonwealth jurisdictions. One criticism is that the emphasis on the court's view of the facts
gives insufficient emphasis to the perception of the public. These criticisms were addressed by the House
of Lords in Porter v. Magill (2001). The Court adjusted the Gough test by stating it to be "whether the fair-
minded and informed observer, having considered the facts, would conclude that there was a real possibility
that the tribunal was biased". This case therefore established the current test in the UK to be one of a "real
possibility of bias".
11. On the other hand, the reasonable suspicion test asks whether a reasonable and fair-minded person sitting in
court and knowing all the relevant facts would have a reasonable suspicion that a fair trial for the litigant is not
possible. Although not currently adopted in the UK, this test has been endorsed by the Singapore courts.
It has been suggested that the differences between the two tests are largely semantic and that the two tests
operate similarly. In Locabail, the judges stated that in a large proportion of the cases, application of the
two tests would lead to the same outcome. It was also held that "[p]rovided that the court, personifying the
reasonable man, takes an approach which is based on broad common sense, and without inappropriate
reliance on special knowledge, the minutiae of court procedure or other matters outside the ken of the ordinary,
reasonably well-informed members of the public, there should be no risk that the courts will not ensure both
that justice is done and that it is perceived by the public to be done". In the Singapore High Court decision Tang
Kin Hwa v. Traditional Chinese Medicine Practitioners Board (2005), Judicial Commissioner Andrew Phang
observed that the real likelihood test is in reality similar to that of reasonable suspicion. First, likelihood is in
fact "possibility", as opposed to the higher standard of proof centring on "probability". Secondly, he suggested
that real in real likelihood cannot be taken to mean "actual", as this test relates to apparent and not actual bias.
He also observed that both the court's and the public's perspectives are "integral parts of a holistic process"
with no need to draw a sharp distinction between them.
In contrast, in Re Shankar Alan s/o Anant Kulkarni (2006), Judicial Commissioner Sundaresh Menon thought
that there was a real difference between the reasonable suspicion and real likelihood tests. In his opinion,
suspicion suggests a belief that something that may not be provable could still be possible. Reasonable
suggests that the belief cannot be fanciful. Here the issue is whether it is reasonable for the one to harbour the
suspicions in the circumstances even though the suspicious behaviour could be innocent. On the other hand,
likelihood points towards something being likely, and real suggests that this must be substantial rather than
imagined. Here, then, the inquiry is directed more towards the actor than the observer. The issue is the degree
to which a particular event is not likely or possible. Menon J.C. also disagreed with both Lord Goff in Gough
and Phang J.C. in Tang Kin Hwa in that he thought the shift of the inquiry from how the matter might appear
to a reasonable man to whether the judge thinks there is a sufficient possibility of bias was "a very significant
point of departure". The real likelihood test is met as long as the court is satisfied that there is a sufficient
degree of possibility of bias. Although this a lower standard than satisfaction on a balance of probabilities,
this is actually directed at mitigating the sheer difficulty of proving actual bias, especially given its insidious
and often subconscious nature. The reasonable suspicion test, however, is met if the court is satisfied that a
reasonable member of the public could harbour a reasonable suspicion of bias even though the court itself
thought there was no real danger of this on the facts. The difference is that the driver behind this test is the
strong public interest in ensuring public confidence in the administration of justice. As of September 2011, the
Court of Appeal of Singapore had not yet expressed a view as to whether the position taken in Tang Kin Hwa
or Shankar Alan is preferable.
Exceptions to the rule against bias
-Necessity
There are cases in which a disqualified adjudicator cannot be replaced, as no one else is authorized to act.
It has been observed that "disqualification of an adjudicator will not be permitted to destroy the only tribunal
with power to act". In such cases, natural justice has to give way to necessity in order to maintain the integrity
of judicial and administrative systems.
This issue regarding necessity was raised in Dimes. The Lord Chancellor had to sign an order for enrolment
in order to allow the appeal to proceed from the Vice-Chancellor to the House of Lords. It was held that his
shareholding in the canal company which barred him from sitting in the appeal did not affect his power to
enroll, as no one but him had the authority to do so. It was mentioned this was allowed "for this [was] a case
of necessity, and where that occurs the objection of interest cannot prevail".
12. -Waiver
The court normally requests that an objection be taken as soon as the prejudiced party has knowledge of the
bias. If an objection is not raised and proceedings are allowed to continue without disapproval, it will be held
that the party has waived its right to do so.
-Effect of a finding of bias
In Dimes, the judges advised the House of Lords that Lord Cottenham's pecuniary interest made his judgment
not void, but voidable. This advice is not wrong in the context of a judicial act under review, where the judgment
will be held valid unless reversed on appeal.
However, in the cases of administrative acts or decisions under judicial review, the court can only intervene
on the grounds of ultra vires, hence making the judgment void. Lord Esher said in Allison v. General Council
of Medical Education and Registration (1894) that the participation of a disqualified person "certainly rendered
the decision wholly void".
Right to a fair hearing
-In general
A hearing of the International Court of Justice in 2006 presided over by its President, Her Excellency Dame
Rosalyn Higgins. A fundamental aspect of natural justice is that before a decision is made, all parties should
be heard on the matter.
It has been suggested that the rule requiring a fair hearing is broad enough to include the rule against bias since
a fair hearing must be an unbiased hearing. However, the rules are often treated separately. It is fundamental
to fair procedure that both sides should be heard. The right to a fair hearing requires that individuals are not
penalized by decisions affecting their rights or legitimate expectations unless they have been given prior notice
of the cases against them, a fair opportunity to answer them, and the opportunity to present their own cases.
Besides promoting an individual's liberties, the right to a fair hearing has also been used by courts as a base
on which to build up fair administrative procedures. It is now well established that it is not the character of the
public authority that matters but the character of the power exercised. However, in the United Kingdom prior to
Ridge v. Baldwin (1963), the scope of the right to a fair hearing was severely restricted by case law following
Cooper v. Wandsworth Board of Works (1863). In R. v. Electricity Commissioners, ex parte London Electricity
Joint Committee Co. (1920), Ltd. (1923), Lord Atkin observed that the right only applied where decision-makers
had "the duty to act judicially". In natural justice cases this dictum was generally understood to mean that a
duty to act judicially was not to be inferred merely from the impact of a decision on the rights of subjects; such
a duty would arise only if there was a "superadded" express obligation to follow a judicial-type procedure in
arriving at the decision.
In Ridge v. Baldwin, Lord Reid reviewed the authorities extensively and attacked the problem at its root by
demonstrating how the term judicial had been misinterpreted as requiring some additional characteristic over
and above the characteristic that the power affected some person's rights. In his view, the mere fact that the
power affects rights or interests is what makes it "judicial" and so subject to the procedures required by natural
justice. This removal of the earlier misconception as to the meaning of judicial is thought to have given the
judiciary the flexibility it needed to intervene in cases of judicial review.
The mere fact that a decision-maker is conferred wide discretion by law is not reason enough for a weakening
of the requirements of natural justice. In the United Kingdom context, this is demonstrated by Ahmed v. H.M.
Treasury (No. 1) (2010). The Treasury had exercised powers to freeze the appellants' financial assets and
economic resources on the ground that it reasonably suspected the appellants were or might be persons who
had committed, attempted to commit, participated in or facilitated the commission of terrorism, pursuant to the
Terrorism (United Nations Measures) Order 2006 and the Al-Qaida and Taliban (United Nations Measures)
Order 2006 made under the United Nations Act 1946. The Supreme Court of the United Kingdom held that since
the Al-Qaida Order made no provision for basic procedural fairness, it effectively deprived people designated
under the order the fundamental right of access to a judicial remedy and hence was ultra vires the power
conferred by the United Nations Act 1946 for the making of the Order.
13. -Article 6 of the European Convention
The right to a fair hearing is also referred to in Article 6(1) of the European Convention on Human Rights and
Fundamental Freedoms, which states:
In the determination of his civil rights and obligations or of any criminal charge against him, everyone is entitled
to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by
law. ...
Article 6 does not, however, replace the common law duty to ensure a fair hearing. It has been suggested
that Article 6 alone is not enough to protect procedural due process, and only with the development of a more
sophisticated common law will the protection of procedural due process extend further into the administrative
machine. Nonetheless, Article 6 supplements the common law. For example, the common law does not impose
a general duty to give reasons for a decision, but under Article 6(1) a decision-maker must give a reasoned
judgment so as to enable an affected individual to decide whether to appeal.
-Aspects of a fair hearing
1Prior notice of hearing
Natural justice allows a person to claim the right to adequate notification of the date, time, place of the hearing
as well as detailed notification of the case to be met. This information allows the person adequate time to
effectively prepare his or her own case and to answer the case against him or her. In Cooper v. Wandsworth,
Chief Justice William Erle went so far as to state that the lack of notice and hearing afforded to Cooper could
be said to be a form of abuse, as he had been treated as if he did not matter. As Lord Mustill famously held in
R. v. Secretary of State for the Home Department, ex parte Doody (1993): "Since the person affected usually
cannot make worthwhile representations without knowing what factors may weigh against his interests fairness
will very often require that he is informed of the gist of the case which he has to answer."
It has been suggested that the requirement of prior notice serves three important purposes:
The interest in good outcomes – giving prior notice increases the value of the proceedings as it is only when the
interested person knows the issues and the relevant information that he or she can make a useful contribution.
The duty of respect – the affected person has the right to know what is at stake, and it is not enough to simply
inform him or her that there will be a hearing.
The rule of law – notice of issues and disclosure of information opens up the operations of the public authority
to public scrutiny.
The British courts have held it is not enough for an affected person to merely be informed of a hearing. He or
she must also be told what is at stake; in other words, the gist of the case.
2Opportunity to be heard
Every person has the right to have a hearing and be allowed to present his or her own case. Should a person
not attend the hearing, even with adequate notice given, the adjudicator has the discretion to decide if the
hearing should proceed. In Ridge v. Baldwin, a chief constable succeeded in having his dismissal from service
declared void as he had not been given the opportunity to make a defence. In another case, Chief Constable
of the North Wales Police v. Evans (1982), a chief constable required a police probationer to resign on account
of allegations about his private life which he was given no fair opportunity to rebut. The House of Lords found
the dismissal to be unlawful. Likewise in Surinder Singh Kanda v. Government of the Federation of Malaya
(1962), a public servant facing disciplinary proceedings was not supplied with a copy of a prejudicial report by
a board of inquiry which the adjudicating officer had access to before the hearing. The Privy Council held that
the proceedings had failed to provide him a reasonable opportunity of being heard.
14. However, this requirement does not necessarily mean the decision-maker has to meet the complainant face
to face – "Natural justice does not generally demand orality". It has been suggested that an oral hearing will
almost be as good as useless if the affected person has no prior knowledge of the case. In Lloyd v. McMahon
(1987), an oral hearing did not make a difference to the facts on which the case was based. Giving judgment in
the Court of Appeal of England and Wales, Lord Justice Harry Woolf held that an oral hearing may not always
be the "very pith of the administration of natural justice". It has also been suggested that an oral hearing is
only required if issues concerning deprivations of legal rights or legally protected interests arise.
3Conduct of the hearing
When deciding how the hearing should be conducted, the adjudicator has to ask whether the person charged
has a proper opportunity to consider, challenge or contradict any evidence, and whether the person is also fully
aware of the nature of the allegations against him or her so as to have a proper opportunity to present his or her
own case. In Secretary of State for the Home Department v. AF (2009), Lord Phillips of Worth Matravers said:
The best way of producing a fair trial is to ensure that a party to it has the fullest information of both the
allegations that are made against him and the evidence relied upon in support of those allegations. Where
the evidence is documentary, he should have access to the documents. Where the evidence consists of oral
testimony, then he should be entitled to cross-examine the witnesses who give that testimony, whose identities
should be disclosed.
However, when a hearing requires the balancing of multiple polycentric issues such as natural justice and
the protection of confidential information for national security reasons, both the concerns of public security
and the right to a fair trial must be adequately met. It was held by the House of Lords in AF, applying the
decision of the Grand Chamber of the European Court of Human Rights A. v. United Kingdom (2009), that a
person accused of terrorism against whom a control order has been issued must be given sufficient information
about the allegations against him to enable him to give effective instructions to his special advocate. If this
requirement is satisfied, a fair hearing can be conducted without detailed disclosure of confidential information
that might compromise national security. On the facts of the case, a special advocate was not permitted further
contact with an applicant or his ordinary legal representatives except with permission of the Special Immigration
Appeals Commission (SIAC) after viewing confidential (or "closed") materials. The House of Lords recognized
that although a special advocate's usefulness is stymied somewhat from having no further instructions after
viewing such materials, if the SIAC decides to issue a control order predominantly on the basis of non-
confidential (or "open") materials, an applicant cannot be regarded as having been denied an opportunity to
challenge the reasonableness of the government's beliefs and suspicions about him. If the evidence against
the applicant is largely closed but allegations contained in open material are sufficiently specific, an applicant
should be able to provide his legal representatives and special advocate with information to refute it (such as
an alibi, if the open material alleges he was at a certain place during a certain period) without having to know
the detail or sources of the closed evidence. However, if the evidence revealed to the person consists only of
general assertions and the case against him is based solely or to a substantive extent on undisclosed adverse
evidence, the fair hearing rule under natural justice will not be satisfied.
In such cases, there are strong policy considerations supporting the principle that a trial procedure can never
be considered fair if a person is kept in ignorance of the case against him or her. First, since the grounds for a
reasonable suspicion that a person is involved in terrorist activity can span from incontrovertible evidence to an
innocent misinterpretation of facts which can be explained away by the person, in many cases it is impossible
for courts to be sure that the disclosure of the evidence will make no difference to the applicant. Secondly,
resentment will be felt by the person and his family and friends if sanctions are imposed without any proper
explanation of the grounds and when, due to the non-disclosure of information, the person is put in a position
where he is unable to properly defend himself. As Lord Phillips put it, "if the wider public are to have confidence
in the justice system, they need to be able to see that justice is done rather than being asked to take it on trust".
15. The right to be heard in answer to charges before an unbiased tribunal is illustrated in the Singapore case
Tan Boon Chee David v. Medical Council of Singapore (1980). During a disciplinary hearing, council members
were either not conscientious about their attendance or did not attend the whole course of proceedings. This
meant they did not hear all the oral evidence and submissions. The High Court held that this had substantially
prejudiced the appellant and constituted a fundamental breach of natural justice. On the other hand, mere
absence from a hearing does not necessarily lead to undue prejudice. It was held in Re Teo Choo Hong (1995)
that the function of a lay member of a lawyers' disciplinary committee was to observe and not cast a vote or
make a judgment. Thus, the appellant had not suffered undue prejudice.
On the basis of reciprocity, if one side is allowed to cross-examine his legal opponent at a hearing, the other
party must also be given the same opportunity. In addition, when a tribunal decides a case on a basis not
raised or contemplated by the parties, or decides it without regarding the submissions and arguments made by
the parties on the issues, this will amount to a breach of natural justice. However, a genuine bona fide mistake
by an adjudicator in omitting to state reasons for not considering a submission is not enough to be a breach
of natural justice. This may occur when the submissions were accidentally omitted, or were so unconvincing
that it was not necessary to explicitly state the adjudicator's findings.
Right to legal representation
There is no inherent common law right to legal representation before a domestic tribunal. A tribunal has the
discretion to admit either a legally qualified or unqualified counsel to assist the person appearing before it,
based on the facts of the case.[94] When assessing whether a party should be offered legal assistance, the
adjudicator should first ask whether the right to be heard applies, and, secondly, whether counsel's assistance
is needed for an effective hearing given the subject matter, bearing in mind the consequences of such a denial.
[95]
In R. v. Secretary of State for Home Department, ex parte Tarrant (1983), Webster J. set out six factors to be
considered when deciding whether to allow representation by counsel, namely:
the seriousness of the charge and the potential penalty;
whether any points of law are likely to arise.;
whether the prisoner is capable of presenting his own case;
whether they are any procedural difficulties faced by prisoners in conducting their own defence;
whether there is reasonable speed in making the adjudication; and
whether there is a need for fairness between prisoners or between prisoners and prison officers.
It has also been suggested that where a tribunal hearing concerns the individual's reputation or right to
livelihood, there is a greater need for allowing legal representation as this vindicates the idea of equality before
the law.
When one refuses legal representation, one cannot expect to receive a higher "standard" of natural justice.
This was enunciated in Singapore in Ho Paul v. Singapore Medical Council (2008).[99] Dr. Ho, who had been
charged with professional misconduct, chose to appear before the Council in person and declined to cross-
examine the Council's key witness. Subsequently, he argued that he should have been warned of the legal
implications of not being legally represented. The High Court rejected this argument and held he had suffered
no prejudice. Dr. Ho had been given a fair opportunity of presenting his own case and, most importantly, had
not been deprived of his right to cross-examine the witnesses.
16. It is also not a court's obligation to provide assistance when a party presents his or her case without legal
representation. In Rajeevan Edakalavan v. Public Prosecutor (1998), the accused had appeared in person
before a magistrate and had entered a plea of guilt. He later petitioned the High Court for criminal revision,
arguing that as the magistrate had not informed him of the defences available to him, his plea had been
equivocal. The Court held:
The onus [of informing the accused of his defence options or what could be more advantageous to his case]
does not shift to the judge (or the Prosecution, for that matter) simply because the accused is unrepresented.
That will be placing too onerous a burden on the judge. Furthermore, the judge will be performing two
completely incompatible and irreconcilable roles – one as the adjudicator, the other as the de facto defence
counsel.
In Singapore, the right to legal representation is contingent on the nature of the inquiry. However, since Article
12 of the Constitution of Singapore guarantees equal protection under the law, it has been suggested that
greater weightage should be accorded to this procedural right when balancing it against the competing demand
of efficiency.
The decision and reasons for it
Currently, the principles of natural justice in the United Kingdom and certain other jurisdictions do not include
a general rule that reasons should be given for decisions. In R. v. Northumberland Compensation Appeal
Tribunal, ex parte Shaw (1951), Denning L.J. stated: "I think the record must contain at least the document
which initiates the proceedings; the pleadings, if any; and the adjudication; but not the evidence, nor the
reasons, unless the tribunal chooses to incorporate them. If the tribunal does state its reasons, and those
reasons are wrong in law, certiorari lies to quash the decision." It has been stated that "no single factor has
inhibited the development of English administrative law as seriously as the absence of any general obligation
upon public authorities to give reasons for their decisions".
Historically, uncontrolled public decisions have led to poor outcomes and disrespect for the decision-makers.
Such decisions also lacked the regularity and transparency that distinguish them from the mere say-so of
public authorities. On such grounds, there are obvious benefits for the disclosure of reasons for decisions. First,
procedural participation by people affected by a decision promotes the rule of law by making it more difficult for
the public authority to act arbitrarily. Requiring the giving of reasons helps ensure that decisions are carefully
thought through, which in turn aids in the control of administrative discretion. Secondly, accountability makes
it necessary for the public authority to face up to the people affected by a decision. When a public authority
acts on all the relevant considerations, this increases the probability of better decision outcomes and, as such,
is beneficial to public interests. Another important benefit is that respect for decision-makers is fostered, which
increases their integrity in the public's eyes.
References
Cases
Kioa v. West (1985) 159 C.L.R. 550 at 583, High Court (Australia).
Knight v. Indian Head School Division No. 19 1990 CANLII 138, [1990] 1 S.C.R. 653, Supreme Court
(Canada).
Locabail (U.K.) Ltd. v. Bayfield Properties Ltd. [1999] EWCA Civ 3004, [2000] Q.B. 451, Court of Appeal
(England and Wales).
Tang Kin Hwa v. Traditional Chinese Medicine Practitioners Board [2005] SGHC 153, [2005] 4 S.L.R.(R.)
[Singapore Law Reports (Reissue)] 604, High Court (Singapore).
Re Shankar Alan s/o Anant Kulkarni [2006] SGHC 194, [2007] 1 S.L.R.(R.) 85, H.C. (Singapore).
17. Other works
Endicott, Timothy [Andrew Orville] (2009), Administrative Law, New York, N.Y.: Oxford University Press, ISBN
978-0-19-927728-5.
Thio, Li-ann (1999), "Law and the Administrative State", in Kevin Y[ew] L[ee] Tan, The Singapore Legal System
(2nd ed.), Singapore: Singapore University Press, pp. 160–229, ISBN 978-9971-69-213-1.
Wade, H[enry] W[illiam] R[awson]; Forsyth, C[hristopher] F. (2009), Administrative Law (10th ed.), Oxford;
New York, N.Y.: Oxford University Press, pp. 369–470, ISBN 978-0-19-921973-5.
Lord Woolf; Jowell, Jeffrey; Le Sueur, Andrew, eds. (2007), "Procedural Fairness: Introduction, History and
Comparative Perspectives", De Smith's Judicial Review (6th ed.), London: Sweet & Maxwell, pp. 317–354,
ISBN 978-0-421-69030-1.
Further reading
Articles and websites
Allan, T[revor] R.S. (1998), "Procedural Fairness and the Duty of Respect", Oxford Journal of Legal Studies
18 (3): 497–515, doi:10.1093/ojls/18.3.497, JSTOR 764676.
Chen, Siyuan; Leo, Lionel (2008), "Natural Justice: A Case for Uniform Rigour: Ho Paul v Singapore Medical
Council [2008] 2 SLR 780; Kay Swee Pin v Singapore Island Country Club [2008] 2 SLR 802", Singapore
Academy of Law Journal 20: 820–833, archived from the original (PDF) on 27 September 2011.
Craig, Paul P. (2003), "The Human Rights Act, Article 6 and Procedural Rights", Public Law: 753–773.
Ho, H[ock] L[ai] (2000), "The Judicial Duty to Give Reasons", Legal Studies 20 (1): 4265, doi:10.1111/
j.1748-121X.2000.tb00132.x.
Leo, Lionel; Chen, Siyuan (2008), "Reasonable Suspicion or Real Likelihood: A Question of Semantics? Re
Shankar Alan s/o Anant Kulkani", Singapore Journal of Legal Studies: 446–454.
Manohar, Sujata V. (November 2007), Principles of Natural Justice [speech at a programme for the orientation
and training of new members, Income Tax Appellate Tribunal, Mumbai, India, 12–28 November 2007], Income
Tax Appellate Tribunal, Mumbai, India, archived from the original on 26 July 2011, retrieved 26 September
2011.
Maurici, James (December 2007), "The Modern Approach to Bias", Judicial Review 12 (4): 251–260.
Books
Aronson, Mark I.; Dyer, Bruce; Groves, Matthew (2009), "Procedural Fairness: The Scope of the Duty; The
Hearing Rule; The Rule Against Bias [chs. 7–9]", Judicial Review of Administrative Action (4th ed.), Sydney:
Thomson Reuters (Professional) Australia Ltd., pp. 403–711, ISBN 978-0-455-22557-9.
Binmore, Ken[neth George] (2005), Natural Justice, New York, N.Y.: Oxford University Press, ISBN
978-0-19-517811-1.
Cane, Peter (2004), "Procedural Grounds of Review [ch. 7]", An Introduction to Administrative Law (4th ed.),
Oxford: Clarendon Press, pp. 133–184 at 133–168, ISBN 978-0-19-926898-6.
Craig, Paul [P.] (2008), "Natural Justice: Hearings; Natural Justice: Bias and Independence [chs. 12–13]",
Administrative Law (6th ed.), London: Sweet & Maxwell, pp. 371–436, ISBN 978-1-84703-283-6.
Jones, David Phillip; de Villars, Anne S. (2009), "Natural Justice and the Duty to be Fair: Historical
Development and General Principles; The Duty to be Fair: Audi Alteram Partem; The Duty to be Fair: The
Rule against Bias [chs. 8–10]", Principles of Administrative Law (5th ed.), Toronto, Ont.: Carswell, pp. 210–
457, ISBN 978-0-7798-2126-6.
Leyland, Peter; Anthony, Gordon (2009), "Procedural Impropriety II: The Development of the Rules of
Natural Justice/Fairness; Procedural Impropriety III: The Requirements of Natural Justice/Fairness [chs.
18. 15–16]", Textbook on Administrative Law (6th ed.), Oxford: Oxford University Press, pp. 342–391, ISBN
978-0199-21-776-2.
Maher, Gerry (1986), "Natural Justice as Fairness", in MacCormick, Neil; Birks, Peter, eds., The Legal Mind:
Essays for Tony Honoré, Oxford: Clarendon Press, pp. 103–120, ISBN 978-0-19-876196-9.
Wan Azlan Ahmad; Nik Ahmad Kamal Nik Mahmod (2006), "Procedural Ultra Vires at Common Law",
Administrative Law in Malaysia, Petaling Jaya, Selangor, Malaysia: Sweet & Maxwell Asia, pp. 119–177, ISBN
978-983-2631-75-0.
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