An applicant claiming a breach of the fair hearing requirement has to prove that he or she suffered substantial injustice since there is no such thing in law as a technical breach of natural justice. The requirements of fair hearing depend on the circumstances of the case such as the nature of the inquiry, the rules governing the tribunal, and the subject matter being dealt with. In general, the rule applies only to conduct leading directly to a final decision, and not to an investigation meant for obtaining information. In "Subbiah Pillai v. Wong Meng Meng" (2001), the Court of Appeal held that there was no right for the solicitor in question to be present every time the Inquiry Committee of the Law Society of Singapore, which had been convened to look into a complaint against him, spoke to a witness. This was because the work of the Inquiry Committee was investigative rather than prosecutorial in nature. Even though the rule is of paramount importance, its application is not universal. The exact ambit of the rule is said to be unclear. The right to be heard refers to the right for a party's case to be heard before a decision is made. Even if a statute does not state the requirement for a hearing, it does not necessarily mean that a hearing will never be required. However, this right is neither automatic nor absolute. For instance, in "Yong Vui Kong", the Court of Appeal noted that at common law a convicted offender seeking mercy had no right to be heard during the clemency process. In Singapore, this situation is reflected by the absence of any provision in Article 22P of the Constitution for an offender to be heard during the clemency process. In "Dow Jones Publishing Co. (Asia) Inc. v. Attorney-General" (1989), the Court of Appeal found that it was not unfair that the Minister for Communications and Information had not given "The Asian Wall Street Journal" a chance to explain why it had published certain articles before declaring that the "Journal" had engaged in Singapore's domestic politics, and restricting its circulation under section 16 of the Newspaper and Printing Presses Act. The Court dismissed the appeal on the grounds that the Minister had not treated the appellant, Dow Jones, unfairly, nor had the appellant been prejudiced in any way by the lack of opportunity to make representations. This was because the appellant had already been warned by the Minister. Furthermore, it was aware from precedent that the Minister was likely to invoke section 16 upon its refusal to publish a letter from the Monetary Authority of Singapore responding to an article, and it had been given many opportunities to publish the letter.