The phrase «principles of fundamental justice» had been borrowed
directly from section 2 (e) of the Canadian Bill of Rights, Canada's proto - Charter enacted
in 1960, and had been interpreted by the Supreme Court to mean that
everyone was entitled to a fair hearing before an impartial tribunal.29 Put another way, fundamental justice incorporated a procedural guarantee synonymous with «natural justice,» meaning that the
state may certainly deprive an individual of life, liberty or security of the person, but only if procedural safeguards have first been met.