148 | Zimbabwe Rule of Law Journal Ors22 where the learned judge made the following observation; “The rules of natural justice as embodied in the audi alteram partem rule require that a person be given reasonable notice to make representations where another takes action which adversely affects his/her interests or rights. The rule as espoused in the Administrative Justice Act [Chapter 10:28] (the Act) require that an administrative authority such as the first respondent, with the responsibility to take an administrative action which may adversely affect the rights or interest of any person, to give that person an opportunity to make adequate representations.”23 Principles of natural justice such as the audi alterum partem principle are meant to ensure that fundamental tenets of fairness are observed in administrative decisions. Professor G. Feltoe summarises the position very well when he observes that; “The principles of natural justice embody fundamental notions of procedural fairness and justice. As applied to administrative decisions, these principles seek to ensure that such decisions are only taken after fair and equitable procedures have been followed. In essence, natural justice tries to guarantee that the parties who will be affected by the decisions receive a fair and unbiased hearing. By required adherence to standards of procedural fairness, not only is justice seen to be done, but also these principles assist administrative decision-makers to reach substantively correct decisions.”24 In this respect, it is of paramount importance to note s 68 of the Constitution has shifted the situations in respect of which principles of natural justice apply. It is useful to briefly restate the old position relating to the application of the principles of natural justice which were to be applicable in situations whereby the affected party had a legitimate expectation to be heard. The concept of legitimate expectation was defined by the South African Appellate division in Administrator, Transvaal & Ors v Traub25 in the following terms; “The legitimate expectation principle, instead of insisting that an individual be affected in his liberty, 22 23 24 25 HH 37/2011 See U-Tow Trailers (Private) Limited v City of Harare & Anor HH 103/09 G Feltoe Ibid. 1989 (4) SA 731 (A)