- (1.) THE concept of fair play is no longer in the realm of judicial consideration but a well-settled principle of law. Fair play and fair treatment being the "soul of natural justice" ought to be the most accepted methodology of all Governmental action. The observations of the Supreme Court in ,the case of (1) Maneka gandhi v. Union of India, reported in AIR 1978 SC 597 seem to be very apposite in his context. The Supreme Court observed : " Natural justice is a great humanising principle intended to invest law with fairness and to secure justice -and over the years it has grown into a widely pervasive rule effecting which arises administrative action. Thus, the soul- of natural justice is the fair play re action and that is why it has received the widest recognition throughout the democratic world".
(2.) THE Supreme Court of New South Wales in the case of Asmand v. Public Service Board of New South Wales it Anr. , reported on 1985 LR (Commonwealth) 1. 041, after noticing the American and English Law as also the development of doctrine of natural justice in the other Commonwealth countries including India observed ; " What cannot be doubted is that there has been a growing body of precedent and other support for the desirability of and sometime the obligations upon, Public Administrative ' Tribunal, at least to state reasons for their decisions effecting seriously the interest of the person seeking those reasons. Sometimes this is expressed to be based on the requirements of natural justice and fairness. Sometimes it is articulated in terms of the inherent necessities of the proper operation of judicial process. . . . . "
(3.) THE general duty of fairness as regards administrative action has also been accepted as a guiding principle by Megarry, J. in the case of bates v. Lord Hailsham, reported in (1972) All ER 12019.;