420. Human rights and natural justice.

It has been held that a party resisting summary enforcement is not able to rely on the right to a fair trial1 under the Convention for the Protection of Human Rights and Fundamental Freedoms (1950)2. The right to a fair trial does not apply to an adjudicator's award or adjudication proceedings because they do not involve a final determination3.

However, an adjudicator is obliged to act impartially4 and in accordance with the rules of natural justice or as fairly as the limitations imposed by Parliament permit5. The court has declined to enforce decisions reached in breach of the rules of