Ridge v Baldwin
Encyclopedia
Ridge v Baldwin [1964] AC 40 was a British legal case heard by the House of Lords
. The judges hearing the case extended the doctrine of natural justice
(procedural fairness) 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 British executive to judicial review
.
The case centred on a decision taken by Brighton police authority
to dismiss its Chief Constable
(Charles Ridge) without offering him an opportunity to defend his actions. The Chief Constable appealed, arguing that the Brighton Watch Committee (headed by George Baldwin) had acted unlawfully (ultra vires
) in terminating his appointment in 1958 following criminal proceedings against him. The court ruled 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. As such, it was the first time that the doctrine had been used to overturn a non-judicial (or quasi-judicial) decision.
Former Chief Constable 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.
Judicial functions of the House of Lords
The House of Lords, in addition to having a legislative function, historically also had a judicial function. It functioned as a court of first instance for the trials of peers, for impeachment cases, and as a court of last resort within the United Kingdom. In the latter case the House's...
. The judges hearing the case extended the doctrine of natural justice
Natural justice
Natural justice is a term of art that denotes specific procedural rights in the English legal system and the systems of other nations based on it. Whilst the term natural justice is often retained as a general concept, it has largely been replaced and extended by the more general "duty to act fairly"...
(procedural fairness) 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 British executive to judicial review
Judicial review in English Law
Judicial review is a procedure in English administrative law by which the courts in England and Wales supervise the exercise of public power on the application of an individual...
.
The case centred on a decision taken by Brighton police authority
Police authority
A police authority in the United Kingdom, is a body charged with securing efficient and effective policing of a police area served by a territorial police force or the area and/or activity policed by a special police force...
to dismiss its Chief Constable
Chief Constable
Chief constable is the rank used by the chief police officer of every territorial police force in the United Kingdom except for the City of London Police and the Metropolitan Police, as well as the chief officers of the three 'special' national police forces, the British Transport Police, Ministry...
(Charles Ridge) without offering him an opportunity to defend his actions. The Chief Constable appealed, arguing that the Brighton Watch Committee (headed by George Baldwin) had acted unlawfully (ultra vires
Ultra vires
Ultra vires is a Latin phrase meaning literally "beyond the powers", although its standard legal translation and substitute is "beyond power". If an act requires legal authority and it is done with such authority, it is...
) in terminating his appointment in 1958 following criminal proceedings against him. The court ruled 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. As such, it was the first time that the doctrine had been used to overturn a non-judicial (or quasi-judicial) decision.
Former Chief Constable 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.