comply with a promise to provide an opportunity for a hearing towards the close of the investigation on whether the duties should be levied, and by departing from certain procedures. Applying Ng Yuen Shiu and the GCHQ case, the Court agreed that the applicant's legitimate expectation had been frustrated by the failure to conduct a hearing, and that it had been unfair for the authorities not to follow the procedures. On the other hand, strong doubts have been expressed about substantive legitimate expectation. In Re Minister for Immigration and Multicultural Affairs; Ex parte Lam (2003), the High Court of Australia said that the reasoning in ex parte Coughlan violated the separation of powers doctrine by overextending the reach of judicial power provided for in section 75(v) of the Constitution of Australia. In its opinion, the balancing act employed in ex parte Coughlan should be left to the executive and falls beyond the province of the courts. Singapore In Singapore, the High Court has recognized that a representation that a consultation will be held before a public authority makes a decision can give rise to a procedural legitimate expectation, though no applicant has successfully established the existence of such an expectation yet. As for the protection of substantive legitimate expectations, in Abdul Nasir bin Amer Hamsah v. Public Prosecutor (1997), a criminal case, the Court of Appeal relied on the concept of legitimate expectations to support the overruling of an incorrect legal principle prospectively – with effect from the date of the judgment – rather than retrospectively which would be the usual effect of a judgment. It stated that "certain legitimate expectations could, in certain circumstances, be deserving of protection, even though they did not acquire the force of a legal right", although it emphasized it was not considering whether the Prisons Department was prevented from carrying out its duties by a legitimate expectation. In UDL Marine (Singapore) Pte. Ltd. v. Jurong Town Corp. (2011), the High Court doubted whether the doctrine of substantive legitimate expectation is part of Singapore law, but did not discuss the matter fully as neither the respondent nor the Attorney-General had made submissions on the issue. Subsequently, in Chiu Teng @ Kallang Pte. Ltd. v. Singapore Land Authority (2013), a differently constituted High Court held that substantive legitimate expectation should be recognized as a ground of judicial review if the following conditions are satisfied: Bangladesh Judicial