11 (i) The rule against bias (nemo judex in causa sua) or that no man should be a Judge in his own cause and (ii) The right to a fair hearing (audi alterem partem) or hear the other side. In fact, the rule of right to a fair hearing is a old as man himself. Thus in R.V University of Cambridge (1723) I Str. 557, Justice Fortescue captured the import of the need for a hearing in the following words: I remember to have heard it observed by a very learned man upon such an occasion that even God himself did not pass sentence upon Adam before he was called upon to make a defence. Adam says God, where art thou? Has thou not eaten of the tree, whereof I commanded thou shouldest not eat? And the same question was put to Eve also. Thus, in Bentley’s case where the University of Cambridge denied a scholar of his degrees on account of a misconduct in insulting the Vice- Chancellor’s Court, the Court reinstated him on a mandamus on the ground that deprivation was unjustifiable, because he should have received the notice of the charge against him so that he could make his defence. These principles are encapsulated in Article 7 of the African Charter. In a nutshell, the rule is that an individual should not be penalized by decisions affecting his rights or legitimate expectations without being given prior notice of the case, a fair opportunity to answer and/or the opportunity to present their own case. The fact that a decision affects rights or interests of a person is sufficient to subject the decision to the procedures required by natural justice. Accordingly, every person has the right to have a hearing and be allowed to present his or her own case. The English cases of Ridge V. Baldwin (1964) AC. 40 and Chief Constable of the Northern Wales Police V. Evans (1982) I WLR 1155 are germane.