1Under s 32(3)(b) of the Magistrates Court (Civil Proceedings) Act 2004 (WA), a denial of natural justice concerns the fairness of the hearing, not the fairness of the outcome. Even if a magistrate erred in fact or law, including by making findings without a proper evidentiary basis, that does not amount to a denial of natural justice. The correctness of a minor case decision on such a basis is not appealable.
2A complaint that a magistrate applied a 'differential standard of scrutiny' to the parties' evidence is, in substance, a complaint about the outcome of credibility assessments. It establishes neither procedural unfairness nor a reasonable apprehension of bias. Likewise, judicial interventions confining a self-represented litigant to relevant questions, rather than argumentative statements, do not deny natural justice. On the facts, such interventions were held entirely proper.
3Reasons in a minor case are adequate if they disclose the essential path of reasoning sufficiently for the litigant to know why they lost and for an appeal court to identify appellable error (DuluxGroup (Australia) Pty Ltd v Chapple [2023] WASCA 83). Whether legally inadequate reasons can themselves constitute a denial of natural justice under s 32(3)(b) remains open.
