Don't see this in ETM's pleadings, but do note that Rio Tinto is using it in relation to the refusal to renew their license at Jabiluka. Very different sort of context, but read the link and I think you will see where I'm going on this.
Natural Juistice - Difficulties Administrators Encounter in Excluding This Common Law Principle
Maybe somebody might even consider referring this paper to our/ETM's beloved leaders (& their/our lawyers)
Common Law Principle of "Natural Justice"
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