The rules of natural justice were originally only two viz.:
1. Audi alteram partem i.e. the person(s) to be affected by an order of the authority should be heard before the order is passed, and
2. The rule against bias.
Subsequently, some more rules of natural justice are in the process of development e.g. that the administrative authority should give reasons for its decisions, particularly when the decisions affect the rights and liabilities of the citizens.
It must, however, be made clear that the rules of natural justice are flexible, and are not a straitjacket formula . In exceptional cases not only can they be modified but even excluded altogether . Natural justice is not an unruly horse. If fairness is shown, there can be no complaint of breach of natural justice .
As regards the rule audi alteram partem, up to 1964 the legal position in England was that in judicial and quasi-judicial proceedings opportunity of hearing had to be given, but it was not necessary to do so in administrative proceedings. This legal position changed in Ridge v. Baldwin in which the House of Lords held that opportunity of hearing had to be given even in administrative proceedings if the administrative order would affect the rights and liabilities of the citizens. This view of the House of Lords was followed by the Supreme Court in State of Orissa v. Dr. Binapani Dei and State of Maharashtra v. Jalgaon Municipal Council wherein it was held that administrative orders which involve civil consequences have to be passed consistently with the rules of natural justice.