Maxwell v. Department of Trade [1974]

Concerned certain rights of
notice in statutory inquiry.
Board of Trade investigated
two companies under provisions of Companies Act.
Plaintiff (Chairman and Chief
Exec) gave evidence.
Was recalled several times to
deal with criticisms other witnesses made against him.
Inspectors made interim
report – highly critical of plaintiff.
Plaintiff argued report made
against rules of natural justice –
Had not had opportunity to
deal with inspectors’ criticisms before report made.
Court of Appeal found against
When inspectors holding
inquiry under Companies Act, sufficient for them to put to witnesses what had
been said against them by others and deal with these criticisms in course of
Not necessary for inspectors
to put tentative conclusions to plaintiff in order to give him opportunity to
Inspectors had acted fairly
and put to plaintiff all matters that appeared to call for answer.