•Landmark case in Malaysian Administrative Law.
•Issue: whether the cancellation of the forwarding agency’s registration is a quasi-judicial act that natural justice will become applicable?
•HC: NJ did not apply, only given RTBH if expressly stated in statute.
•FC: overruled HC decision and upheld that natural justice was applicable for the matter of cancellation of the agency despite the fact that there is no provision governed in the statute.
•The court emphasized that the rule requiring a fair hearing is very crucial because it can be used to display the whole idea of an administrative procedural rights in accordance with the famous landmark case of Ridge v Baldwin
•Relevant principle of NJ - no man shall be condemned unheard.
•Apply where an individual is adversely affected by an administrative action be it ‘judicial’, ‘quasi-judicial’ or ‘administrative’ or whether or not the existing statute provide provision for hearing.
This case marks the shift in approach to concept of Natural Justice in Malaysia, from wide interpretation to the doctrine of fairness.