The amount of due process available to a party is not limited in a proceeding before an administrative agency. In Allegheny County Health Department v. Ligons, 329 A.2d 878, 879 (Pa.Cmwlth. 1974), we said, We have held in other cases that local regulatory agencies must provide to any party charged with a violation of the law the same due process protection provided citizens in any other kind of legal action.
This is because when the lower court hears an appeal from a governmental agency de novo, the burden is upon the governmental body "to prove all of the elements, both procedural and substantive, necessary to support its adjudication." Allegheny County Health Department v. Ligans, 16 Pa. Commw. 74, 329 A.2d 878 (1974). Upon our review of the transcript of the de novo hearing, we find that the trial court did not manifestly abuse its discretion.
Also, this Court has examined the procedural due process considerations of some aspects of the act. Allegheny County v. Ligons, 16 Pa. Commw. 74, 329 A.2d 878 (1974); Davis v. Allegheny Co. Health Dep't, 16 Pa. Commw. 13, 328 A.2d 589 (1974). The issue on appeal, however, has not been previously raised.