Since the 1950s, the types of interests attracting the rules of natural justice have gradually expanded. In 2012, this expansion culminated in Plaintiff S10/2011 v Minister for Immigration & Citizenship (2012) 246 CLR 636, where the plurality simply adopted an "interest" as the sole trigger for the application of natural justice (subject to other principles) and equated that interest to the interest that gives a person standing. This new approach arguably excludes very few interests from procedural obligations. More recently, the plurality in Isbester v Knox City Council (2015) 89 ALJR 609 has introduced even vaguer terminology, so that, provided the interest in question is important to many people, natural justice will be owed. This article provides a short critique of this new approach to the natural justice threshold question, arguing that greater clarification is needed on its exact scope and application. This article is by no means a thorough account, but rather it aims to highlight a few areas in need of exploration.
