al and not limited in operation. Moreover, if regulations, which
are general in their application, may be readily subjected to judicial
challenge after their promulgation, or if the parties to which they
apply are affected only when they endeavor to comply in the future,
advance notice and hearing is less likely to be viewed as essential to
due process.[741]

As to that portion of administrative activity pertaining to the making
of determinations or the issuance of orders of limited or individual
application, the obligation to afford notice and hearing is reasonably
clear; but controversy has been protracted on the question whether this
procedural safeguard, in every instance, must be granted in advance of
such activity. The most frequently litigated types of administrative
action embracing the latter issue have been determinations to withhold
issuance of, or to revoke, an occupational license, or to impound or
destroy property believed to be dangerous to public health, morals, or
safety. Apparently in recognition of the fact that few occupations today
can be pursued without a license, the trend of decisions is toward
sustaining a requirement of a hearing before refusal to issue a license
and away from the view that inasmuch as no one is entitled as of right
to engage in a specific profession, the issue of a practitioner's
license applicable thereto is in the nature of a gift as to the granting
or withholding of which procedural protection is unnecessary.
Revocation, or refusal to renew a license, however, has been
distinguished from issuance of a license; and where a license is
construed to confer something in the nature of a property right rather
than a mere privilege terminable at will, such property right, the
Courts have maintained, ought not to be destroyed summarily by
revocation without prior notice and hearing. Whether an occupational
license is to be treated as a privilege revocable without a hearing, or
as conferring a property right deserving of greater protection, depends
very largely on prevailing estimates of the social desirability of a
calling. Thus, if a business is susceptible of being viewed as injurious
to public health, morals, safety, and convenience, as, for example,
saloons, pool rooms, and dance halls, the licensee is deemed to have
entered upon such line of endeavor with advance knowledge of the State's
right to withdraw his license therefor summarily. Prompt protection of
the public in such i