the alleged conspirators could be fairly confronted with the allegation.
See the speech of Lord Russell of Killowen in _Fairmount Investments
Ltd._ v. _Secretary of State for the Environment_ (1976) 2 All E.R. 865,
and the judgement of Lord Parker C.J. in _Sheldon_ v. _Bromfield
Justices_ (1964) 2 Q.B. 573, 578. In fact in the present case but for a
far less significant reason the Commissioner himself actually considered
the possible need to reconvene the hearing after certain enquiries had
been made on his instructions following the taking of evidence in
public. The matter is mentioned in paragraph 358 of the Report.

_Landreville_ v. _The Queen_ (No. 2) (1977) 75 D.L.R. (3d.) 380,
402-405, was decided in the end on just such a ground. It was held that
a Commissioner, who happened to be a distinguished Judge, had failed to
put to the person whose conduct was expressly subjected to investigation
by the terms of reference of the Commission a very serious allegation
upon which a finding was made in the report; and that the Commission
should have been reconvened for that purpose. There the relevant rule of
natural justice was fully embodied in a statutory provision. We think
that the position is the same under the New Zealand Commissions of
Inquiry Act supplemented by the common law.

All these considerations suggest that the Commission was bound by the
broad requirements of natural justice. These included a reasonable
opportunity of meeting the unformulated allegation of organized
deception and concealment that was apparently passing through the
Commission's mind. Some of the reasons why experience has shown the
importance of this sort of opportunity were well put by Megarry J. in
_John_ v. _Rees_ (1970) 1 Ch. 345, 402.:

"It may be that there are some who would decry the importance which