Baker also argued that the duty of fairness owed to her by the Minister included a duty to provide reasons for any decision made. The court looked to English jurisprudence, in which a common law right to reasons in certain circumstances has developed in the case law. The court found that it would be unfair for the Minister not to provide written reasons for refusing an application in a case such as this where the decision has such significance for the individual and where there is a statutory right of review or appeal of the decision. The court allowed some flexibility in what constitutes reasons, and in this case allowed the notes given by the subordinate officer to the decision-maker to be treated as the reasons for the decision.