Panda Toys Exports (Pvt) Ltd. vs Commissioner-General of Labour and Others – sllr 2008 volume 2 page 089

In Panda Toys Exports (Pvt) Ltd. v. Commissioner-General of Labour and others, the court examined the validity of a compensation order by the 1st respondent, which was based on the recommendation of an officer who did not personally conduct the inquiry, raising the legal issue of adherence to the procedural principle that “he who hears must decide.” It was held that such delegation, where the decision-maker had not heard the evidence, rendered the order ultra vires and procedurally invalid. Reliance was placed on authorities including Kundanmal Industries Ltd. v Wimalasena and Nagalingam v Lakshman de Mel, emphasizing that procedural fairness and lawful delegation in administrative proceedings are critical. The case clarifies and reiterates that orders must be based upon the decision of th