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.