Lord Fraser of Tullybelton in ATTORNEY-GENERAL OF HONG KONG V. NG YUEN SHIU (1983) 2 A.C. 629 said that, “When a public authority has promised to follow a certain procedure, it is in the interest of good administration that it should act fairly and should implement its promise, so long as implementation does not interfere with its statutory duty”.
Council of Civil Service Unions and Ors. v. Minister for the Civil Service (1984)3 All E.R. 935 where it was held, inter alia, that an aggrieved person was entitled to invoke judicial review, if he showed that a decision of a public authority affected, him by depriving him of some benefits or advantage which in the past he had been permitted to enjoy and which he legitimately expected to be permitted to continue to enjoy, either until he was given reasons for its withdrawal and the opportunity to comment on those reasons, or because he had received an assurance that it would not be withdrawn before he had been given the opportunity of making representations against the withdrawal. It was further held that the appellant’s legitimate expectation arising from the existence of a regular practice of consultation which the appellant could reasonably expect to continue, gave rise to an implied limitation on the Minister’s exercise of the power contained in Art. 4 of the Civil Service Order in Council, 1982 namely, an obligation to act fairly by consulting the civil service staff before withdrawing the benefit of trade union membership.