Ridge v Baldwin

Ridge v Baldwin [1964] AC 40 was a UK labour law case heard

Ridge v Baldwin
by the House of Lords.[1] The decision extended the doctrine of
natural justice (procedural fairness in judicial hearings) into the
realm of administrative decision making. As a result, the case has
been described as "the landmark case" that opened up decisions
taken by the UK executive to judicial review in English law.[2]

Contents
Facts
Court House of Lords
Judgment
Decided 14 March 1963
Significance
Citation(s) [1964] AC 40, [1963]
Notes
UKHL 2 (http://www.bai
lii.org/uk/cases/UKHL/
Facts 1963/2.html)
Court membership
The Brighton police authority dismissed its Chief Constable Judge(s) Lord Reid, Lord
(Charles Ridge) without offering him an opportunity to defend his sitting Evershed, Lord Morris
actions. The Chief Constable appealed, arguing that the Brighton of Borth-y-Gest, Lord
Watch Committee (headed by George Baldwin) had acted
Hodson, and Lord
unlawfully (ultra vires) in terminating his appointment in 1958
Devlin
following criminal proceedings against him.[1]

Ridge also sought financial reparation from the police authority; having declined to seek reappointment, he
sought a reinstatement of his pension, to which he would have been entitled with effect from 1960 had he
not been dismissed, plus damages, or salary backdated to his dismissal.[3]

Judgment
The House of Lords held that Baldwin's committee had violated the doctrine of natural justice, overturning
the principle outlined by the Donoughmore Committee thirty years before that the doctrine of natural justice
could not be applied to administrative decisions.

Significance
"Natural justice" is a legal doctrine which requires an absence of bias (nemo iudex in causa sua) and the
right to a fair hearing (audi alteram partem). Ridge was the first time that the doctrine had been used to
overturn a non-judicial (or quasi-judicial) decision.[2]

Notes
 1. Slapper, Gary (24 June 2008). "The cases that changed Britain: 1955-1971" (http://business.
timesonline.co.uk/tol/business/law/article4197113.ece). The Times. Retrieved 4 September
2011.
2. Gillian Peele (2004). Governing the UK: British politics in the 21st century (https://archive.or
g/details/governingukbriti0004peel) (4th ed.). Wiley-Blackwell. p. 475 (https://archive.org/det
ails/governingukbriti0004peel/page/475). ISBN 978-0-631-22681-9. Retrieved 28 August
2011.
3. "Mr Ridge's dismissal held in breach of natural justice" (http://archive.timesonline.co.uk/tol/vi
ewArticle.arc?articleId=ARCHIVE-The_Times-1963-03-15-16-005&pageId=ARCHIVE-The_
Times-1963-03-15-16). The Times. 15 March 1963. Retrieved 4 September 2011.

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