Ridge v. Baldwin (1964)

In Ridge v. Baldwin [1964] AC 40, the House of Lords said that a public authority cannot remove a person from office without first giving clear notice of the charges and a chance to defend. Because Mr. Ridge was dismissed without any hearing, the decision was void.

• Natural justice is a baseline duty for administrative decisions.
• “Hear the other side” (audi alteram partem) is not optional.
• Powers under statute must be used fairly and lawfully.

1. Was the dismissal void because the Watch Committee ignored natural justice?
2. Did the Committee act within the Municipal Corporations Act, 1882?
3. Did failing to follow the Police (Discipline) Regulations make the dismissal procedurally invalid?

• Authorities must give notice and a real opportunity to be heard.
• Administrative action must stay within the statute and avoid arbitrariness.
• Decisions made without natural justice are void, not just voidable.

Held: The House of Lords allowed the appeal. The dismissal was null and void because Ridge was not given notice of the allegations or an opportunity to respond. Statutory power under the 1882 Act must be exercised with procedural fairness, and the Police (Discipline) Regulations applied and required safeguards.

The case was remitted for further proceedings consistent with these principles.

• Where a decision affects status, office, or rights, natural justice must be observed.
• Audi alteram partem (notice + fair hearing) is a condition on the power to dismiss.
• Breach of natural justice makes the act void.

This case reset the focus on fair procedure in administrative law. It protects people from sudden, unreasoned removals by public bodies and guides decision-makers to act lawfully and fairly.

Mnemonic: R I D G E → Reason, Inform, Defend, Guided by law, Effect = void if unfair.

Issue

Was the dismissal valid when done without notice or hearing?

Rule

Natural justice: notice + fair hearing; statutory power must be used fairly; breach makes the act void.

Application

Ridge was dismissed summarily. No prior notice, no chance to answer. The Committee acted without following the Police (Discipline) Regulations and fairness.

Conclusion

Dismissal was void; appeal allowed; case remitted.

Natural Justice

Basic fairness rules in decision-making.

Audi Alteram Partem

Hear the other side—notice and hearing.

Void

Legally ineffective from the start.