hand. This exception is prompted by the overriding imperative of equality. Thus, the applicant need not have had detailed knowledge or the existence of the policy in order for a legitimate expectation to arise where the public authority had departed from the existing policy in deciding the individual case. Strong reliance by the applicant is not compulsory to prove the existence of a legitimate expectation. In spite of this, Lord Justice of Appeal Peter Gibson stated in R v Secretary of State for Education and Employment, ex parte Begbie (1999) that "it would be wrong to understate the significance of reliance in this area of the law". Detrimental reliance is not indicative of whether the court should protect an applicant's legitimate expectation but usually furthers an applicant's case, and it is only in exceptional cases where courts will protect a legitimate expectation in which detrimental reliance is absent. Procedural legitimate expectations A procedural legitimate expectation by an individual or group rests on the presumption that the decision-maker will follow a certain procedure in advance of a decision being taken. This expectation can manifest in various ways, such as the expectation of being consulted; of an inquiry being held; of a fair hearing; and of being allowed time to make representations, especially where the applicant is seeking to persuade an authority to depart from a lawfully established policy. The courts' protection of procedural legitimate expectations reinforces the notion that administrative decision-makers should be bound by certain representations which they make to individuals who stand to be affected by their decisions. Rooted in the principle of natural justice, procedural legitimate expectation protects procedural interests of the individual in public law. Although procedural expectations by applicants may manifest in various forms, they are all aspects of the "right to a hearing", which an individual affected by a decision enjoys. The UK courts developed this doctrine largely to ensure that the rules of natural justice are observed, to encourage good administration and prevent abuses by decision-makers. Development of procedural protection A key step in the development of procedural legitimate expectation was the observation of Lord Fraser of Tullybelton in Attorney-General of Hong Kong v. Ng Yuen Shiu (1983) that "when a public authority has promised to follow a certain procedure, it is in the interest of good administration that it should act fairly and should implement its promise, so long as implementation does not