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 1 October 1993, a five-judge Constitution Bench held that a delinquent employee is entitled to a copy of the inquiry officer's report before the disciplinary authority decides — but tempered the remedy with a prejudice test, making non-supply void only where the employee shows prejudice.