The breadth of the audi alleram partem principle was, however, limited in the first half of this century. The courts held that a hearing would only be required if the body was acting judicially rather than administratively (Errington v. Minister 0f Health [1935] 1 KB. 249); there was misunderstanding over remedies, particularly the scope of certiorari, which affected the applicability of natural justice; and some courts held that natural justice would only apply to protect rights and not privileges (Nrzk/tuda Ali [1951] A.C. 66,77-78; Bailey v. Richardson 182 F 2d 46 (1950)).