LEGAL PRINCIPLE: ADMINISTRATIVE LAW — Natural Justice — Fair Hearing — Irrelevance of Correctness of Decision Where Procedure is Flawed
PRINCIPLE STATEMENT
Once a decision is reached in breach of natural justice, the justness or correctness of the decision is irrelevant; the decision cannot stand regardless of its merits.
RATIO DECIDENDI (SOURCE)
Per Kalgo, JSC, in Psychiatric Hospitals Management Board v. Edosa (2001) NLC-1631995(SC) at p. 15; Paras C–E.
"The question is not whether the decision of the Board was wrong or right. Once it acted within its jurisdiction as provided under section 13 of the Act, the justness or correctness of its decision is irrelevant provided the rules of natural justice were observed, which were breached in this case."
EXPLANATION / SCOPE
A decision reached in violation of natural justice is invalid regardless of its substantive correctness. The court does not examine whether the decision was right or wrong on the merits. The procedural defect alone is fatal. The principle emphasises that fair procedure is a fundamental right, not dependent on outcome. Even a perfectly correct decision cannot stand if the affected party was denied a fair hearing. The rule applies to administrative bodies, tribunals, and courts. The remedy is to set aside the decision and require a fresh hearing complying with natural justice. The principle prevents the justification of procedural violations by substantive correctness.