On 31 March 2005, a two-judge bench restated the contours of natural justice — its flexibility, the primacy of audi alteram partem, the governing role of prejudice, and the capacity of a post-decisional hearing to cure a deficient pre-decisional one.
On 4 September 1990, a Constitution Bench of five judges struck down a 'hire and fire' clause permitting termination of permanent employees without reasons and without hearing — holding that audi alteram partem must be read into State termination powers and that arbitrary, unguided dismissal violates Article 14.