OPINION OF THE COURT
This is an appeal instituted by a physician, Samuel S. Lyness, M.D., whose license to practice medicine and surgery in the Commonwealth of Pennsylvania was revoked by the State Board of Medicine, after that Board initiated disciplinary hearings and concluded that Dr. Lyness had committed acts constituting immoral and unprofessional conduct in violation of the Medical Practice Act.1
The issue on appeal is whether a violation of due process occurs under the Pennsylvania Constitution when an administrative board, such as the State Board of Medicine, both determines that a professional licensing prosecution should be initiated, and then acts as the ultimate fact-finder in determining whether a violation has occurred. More specifically, this Court must address whether such a commingling of prosecutorial and adjudicative functions within a single multi-member administrative board is consistent with this Court’s previous decision in Dussia v. Barger, 466 Pa. 152, *537351 A.2d 667 (1975). For the reasons that follow, we conclude that such a commingling is not consistent with the notion of due process embodied in the Pennsylvania Constitution.
FACTUAL BACKGROUND
On January 8, 1985, an emergency meeting was called of the State Board of Medical Education and Licensure, forerunner of the present State Board of Medicine (hereinafter “Board”). The Board is an administrative body established by statute in Pennsylvania, with the authority to license, investigate complaints and impose disciplinary sanctions with respect to medical professionals practicing in the Commonwealth. See Medical Practice Act of 1985, Act of December 20, 1985, Pub.L. No. 457, as amended, 63 P.S. § 422.1 et seq. (Purdon Supp.1990).2
Acting at the request of the Board’s prosecuting attorney, Joseph E. Hagan, Esquire,3 Board Chairperson Barbara K. Shore, Ph.D. convened the emergency meeting by telephone conference call. Eight members of the eleven-person Board were in attendance.4 The subject of the meeting was to consider whether Mr. Hagan would be *538authorized to cite physician Samuel S. Lyness, M.D. (Lyness) for a formal hearing, based upon a complaint of sexual molestation of a female patient which had been brought to his attention.
Mr. Hagan represented to the Board that he had investigated a patient complaint which raised the following allegation. On November 26, 1984, Dr. Lyness had performed a partial craniotomy on a 17-year-old female patient (“A.Z.”). Two days later, on November 28, 1984, the patient filed a report with local police alleging that on the prior evening, while in intensive care recovering from brain surgery, Dr. Lyness had fondled her vagina and placed his penis in her mouth.
Following discussion by the Board, seven out of the eight members in attendance voted to cite Dr. Lyness for a formal hearing, essentially determining that sufficient evidence existed to initiate disciplinary action. Only Board member Donald C. Reid, M.D., abstained. Prosecutor Hagan, on January 9, 1985, therefore issued an Administrative Complaint and Order to Show Cause, lodging formal charges against Dr. Lyness. The Complaint was issued under the signature of Barbara K. Shore, Ph.D., Chairperson of the Board.
In accordance with procedures established under Article IX of the Health Care Services Malpractice Act (“Malpractice Act”), Act of October 15, 1975, Pub.L. No. 390, as amended, 40 P.S. § 1301.901 thru § 1301.907, and various administrative regulations promulgated thereunder, see 49 Pa.Code § 16.41 (1987) et seq., the Board appointed a neutral Hearing Examiner, Louis E. Seltzer, Esq., to preside over the disciplinary proceedings initiated against Dr. Lyness. Testimony was commenced in February of 1985; however, criminal charges were filed against Dr. Lyness in several county courts in Pennsylvania. The Commonwealth Court stayed the administrative hearings before the Board, in order that these would not in any way taint pending criminal proceedings involving Dr. Lyness.
*539Dr. Lyness was acquitted of all charges by juries in Montgomery and Delaware Counties. Board hearings thereafter resumed in front of Hearing Examiner Seltzer. The original Administrative Complaint was amended to include seven additional counts against Dr. Lyness, involving six additional female patients who had come forward alleging sexual molestation similar to that described in the original Complaint. These new incidents took place over a period of eight years, between 1976 and 1984, and generally involved patients alleging that they had awoken from sedation to find Dr. Lyness engaged in sex acts with them.
Lengthy hearings on all charges were conducted by the Board-appointed Hearing Examiner between September, 1985 and September, 1986. On June 22, 1987, Hearing Examiner Seltzer issued his Adjudication and Order, finding that the allegations of six out of the seven Complainants were “overwhelmingly credible.” His formal order directed that Dr. Lyness’ license be suspended for a period of five years, and that Dr. Lyness submit himself to treatment by a physician (presumably a psychiatrist) designated by the Board.
Both Dr. Lyness and the Board’s prosecuting attorney filed an application for review to the Board, as authorized by Section 905 of the Malpractice Act, 40 P.S. § 1301.905, which effectively permits de novo review of the Hearing Examiner’s findings by the Board. On March 22, 1988, the Board convened a meeting and voted to affirm the factual findings of the Hearing Examiner. However, the Board found the sanction imposed by the Hearing Examiner to be inconsistent with the gravity of the misconduct, and instead ordered the permanent revocation of Dr. Lyness’ license to practice medicine and surgery in the Commonwealth. The vote in favor of this action was six in favor, one abstention.5 Of the original members of the Board who had voted to *540initiate prosecution against Dr. Lyness in January of 1985, three Board members (Barbara K. Shore, Ph.D., Guy L. Kratzer, M.D. and James, M.D.) participated in the meeting in March of 1988 at which Dr. Lyness’ license was revoked; Ms. Shore did not cast a vote because she presided over the meeting.6
On April 22, 1988, Dr. Lyness filed a Petition for Review in Commonwealth Court, alleging inter alia that there existed an improper commingling of prosecutorial and adjudicatory functions by the Board. The Commonwealth Court, in an en banc decision, affirmed the order of the State Board of Medicine. See Lyness v. Commonwealth of Pennsylvania State Board of Medicine, 127 Pa.Commw. 225, 561 A.2d 362 (1989). The Commonwealth Court rejected Dr. Lyness’ argument that a multi-member administrative board, such as the State Board of Medicine, which performs both prosecutorial and adjudicatory functions constitutes a per se violation of due process. In reaching this conclusion the Commonwealth Court relied heavily upon its own decision in Oppenheim v. Department of State, 74 Pa.Commw. 200, 459 A.2d 1308 (1983). Oppenheim held that a pre-hearing determination of probable cause by an administrative board did not result in a per se invalid adjudication “as long as the prosecutorial and investigatory aspects of the matter are adequately separated from the adjudicatory function.”7 The court below also distinguished the instant case from our previous decision in *541Dussia, on the thread of logic that the Instant case involved a multi-member board, whereas Dussia involved a single individual serving as both prosecutor and adjudicator. Lyness, 127 Pa.Commw, at 228, 561 A.2d at 365. The Commonwealth Court nevertheless vacated the decision of the Board, and remanded for further proceedings; however, their conclusion related strictly to the issue of laches, which is not relevant in the instant appeal.8
On October 15, 1990, this Court granted Dr. Lyness’ Petition for Allowance of Appeal limited to the due process issue regarding the improper commingling of the Board’s prosecutorial and adjudicatory functions. The petition was denied in all other respects.
DISCUSSION
The guarantee of due process of law, in Pennsylvania jurisprudence, emanates from a number of provisions of the Declaration of Rights, particularly Article I, Sections 1, 9 and 11 of the Pennsylvania Constitution.9 These provisions in turn enjoy a long history in the Commonwealth, tracing *542their way back to early documents, including the English Magna Charta. See T. White, Constitution of Pennsylvania 114 (1907). As we have stated in the past, in attempting to shed light on the procedural face of due process: “[wjhile not capable of exact definition, the basic elements of procedural due process are adequate notice, opportunity to be heard, and the chance to defend oneself before a fair and impartial tribunal having jurisdiction of the case.” Commonwealth v. Thompson, 444 Pa. 312, 316, 281 A.2d 856, 858 (1971).
This Court has recognized as well established the principle that “due process is fully applicable to adjudicative hearings involving substantial property rights____” Soja v. Pa. State Police, 500 Pa. 188, 193, 455 A.2d 613, 615 (1982). Such property rights perforce include the right of an individual to pursue a livelihood or profession, thus triggering the protective mechanism of procedural due process. See, e.g., Roche v. State Board of Funeral Directors, 63 Pa. Commw. 128, 437 A.2d 797 (1981). A fortiori, this is true where, as here, an administrative board is empowered by the State to regulate the conduct of professionals and ultimately impose sanctions which may include the revocation of a license to practice medicine in the Commonwealth.
In determining what process is due Pennsylvania citizens, this Court has established a clear path when it comes to commingling prosecutorial and adjudicatory functions. There is a strong notion under Pennsylvania law that even an appearance of bias and partiality must be viewed with deep skepticism, in a system which guarantees due process to each citizen. Consequently, this Court in Dussia struck down a regulation which vested power in a police commissioner to both initiate court-martial proceedings against a state police officer (a prosecutorial function), and thereafter exercise ultimate judicial determination as to guilt or innocence.10 Then-Justice, now Chief Justice Nix, writing for this Court in Dussia, made clear that “actual bias” was not the watchword in ferreting out violations of due process *543under the Pennsylvania Constitution. As this Court had written earlier in Schlesinger Appeal, 404 Pa. 584, 172 A.2d 835 (1961):
Moreover, a predilection to favor one side over the other is not required in order to vitiate a judicial proceeding as being violative of due process. Merely, ‘a possible temptation to the average man as a judge ... not to hold the balance nice, clear, and true’ is sufficient.”
Id. 404 Pa. at 598, 172 A.2d at 841.
Justice Nix concluded in Dussia that the overlap of prosecutorial and adjudicatory functions, even where not complete, was anathema to the notion of due process in Pennsylvania, where citizens rightly presume that the same individual does not wear the mantel of zealous prosecutor and impartial judge. Justice Nix wrote:
While in the instant case the Commissioner did not in fact have the responsibility of the entire prosecutorial role, we do not believe that this fact alone is sufficient basis for distinguishing the instant case from the authorities cited Supra. The decision to institute a prosecution is such a fundamental prosecutorial function that it alone justifies concluding a dual capacity where the individual also is charged with the responsibility of making the ultimate determination of guilt or innocence. Moreover, it is a decision which requires a judgment as to the weight of the evidence against the accused, a judgment which is incompatible with the judicial function of providing an impartial forum for resolution of the issues presented.
Dussia, 466 Pa. at 165, 351 A.2d at 674 (emphasis added.)
The Commonwealth Court’s attempt in the instant case to distinguish Dussia on the basis that Dussia involved a *544single individual, rather than (as here) a multi-member Board, rings hollow at best. Due process is not swept under the carpet simply because it is transgressed by a group of people, rather than a single individual. Indeed, the due process guaranty of the Pennsylvania Constitution is primarily directed at governmental (i.e. state) action, which generally presumes action of a municipal, administrative, or state governmental body, rather than a single individual.
Nor is the threat to due process inconsequential where eight members of an administrative board (here the Board of Medicine), wear the hat of the prosecutor and make the determination that probable cause exists to bring formal charges; and then the same board — with a number of members identical — later wears the robe of. the judge to make a presumably impartial adjudication which will determine the fate of a physician’s license to practice medicine in this Commonwealth. Whether it is one person or eight who merge the prosecutorial and adjudicatory roles, the danger is equally serious.
Thus, a mere possibility of bias under Pennsylvania law is sufficient to raise the red flag of protection offered by the procedural guaranty of due process. Not only does our decision in Dussia make this point explicit, but a steady string of cases over the past three decades has firmly established such a principle as a matter of Pennsylvania law. In Gardner v. Repasky, 434 Pa. 126, 252 A.2d 704 (1969), this Court invalidated a procedure whereby the same individual was a member of the Fire Board which brought the initial complaint against a police officer, and the Civil Service Commission which heard the officer’s appeal, thereafter suspending him. In Gardner, Mr. Justice Cohen stressed that the mere appearance of bias must be avoided, and concluded: “A man cannot sit as judge when he is a member of a board which has brought the accusations.” Id. 434 Pa. at 130, 252 A.2d at 706.
In Commonwealth, Department of Insurance v. American Bankers Insurance, 478 Pa. 532, 387 A.2d 449 (1978), *545this Court in a per curiam opinion invalidated administrative sanctions imposed by the Insurance Department of the Commonwealth of Pennsylvania, which had charged American Bankers Insurance Company of Florida with transgressions of the Pennsylvania insurance laws. The associate general counsel of the Insurance Department had supervised the office which initiated charges, and then sat as a Commissioner presiding over the hearings. This Court wrote: “Such a commingling of prosecutorial and adjudicatory functions in one individual offends fundamental notions of due process and is constitutionally impermissible.” Id., 478 Pa. at 534, 387 A.2d at 450.
Moreover, the instant case is quite different from the situation presented in State Dental Council and Examining Board v. Pollock, 457 Pa. 264, 318 A.2d 910 (1974), relied upon heavily by the Board in its brief. Pollock, a pre-Dussia decision also authored by then-justice now Chief Justice Nix, involved a determination of the State Dental Council and Examining Board to suspend Dr. Pollock’s license to practice dentistry for allowing an unlicensed assistant to perform work as a dentist. Dr. Pollock asserted that his due process rights had been violated because the complaint was received by the Dental Board, an investigation was conducted by the Law Enforcement Bureau of the Commission of Professional and Occupational Affairs (a distinct administrative entity under the Pennsylvania Department of State), and an assistant attorney general in the Legal Office of that Commission prosecuted the case before the Board. Pollock, 457 Pa. at 269, 318 A.2d at 714. In concluding that there was no violation of appellant’s due process rights under such facts, this Court stated:
It is not uncommon for large agencies to fulfill both the prosecutory and judicial functions (e.g., the Federal Trade Commission and the Public Utilities Commission). So long as the functions are separated adequately, Due Process is preserved ... A fortiori, there is no Due Process violation in the administrative structure employed here, where both functions were handled by *546distinct administrative entities with no direct affiliation to one another ... The cases cited by appellant such as Schlesinger, supra; Gardner, supra; and Murchison, supra, where the same individuals actually participated in both prosecutory and judicial roles are clearly distinguishable.
Id., 457 Pa. at 271-72, 318 A.2d at 914-15. (emphasis added).11
Pollock and similar cases stand only for the sensible proposition that in the modern world of sprawling governmental entities akin to corporations it would be both unrealistic and counterproductive to insist that administrative agencies be forbidden from handling both prosecutorial and adjudicatory functions, where such roles are parcelled out and divided among distinct departments or boards. Efficiency and cost-effectiveness are certainly desirable ends. Indeed, each administrative board and judge is ultimately a subdivision of a single entity, the Commonwealth of Pennsylvania, but this does not render their collective work as prosecutors, investigators and adjudicators constitutionally infirm, nor create an imminent threat of prejudice.
What our Constitution requires, however, is that if more than one function is reposed in a single administrative entity, walls of division be constructed which eliminate the threat or appearance of bias. As then-Justice Nix stated so percipiently in concurrence in American Bankers, a “mere tangential involvement” of an adjudicator in the decision to initiate proceeding is not enough to raise the red flag of procedural due process. American Bankers, 478 Pa. at 545, 387 A.2d at 456. Our constitutional notion of due process does not require a tabula rasa. Soja, 500 Pa. at 197, 455 A.2d at 617. However, where the very entity or individuals involved in the decision to prosecute are “signifi*547cantly involved” in the adjudicatory phase of the proceedings, a violation of due process occurs. American Bankers, 478 Pa. at 546, 387 A.2d at 456. (Nix, J. concurring). Such a conclusion is only made more compelling where, as here, the administrative Board has virtual carte blanche in reviewing the Hearing Examiner’s findings and replacing it with its own adjudication, with very limited appellate review in the Commonwealth Court.12
In the instant case, the procedures followed by the Board, pursuant to the applicable administrative regulations, clearly created an unconstitutional intermingling of the prosecutorial and adjudicatory functions in a single entity. Allegations of misconduct were investigated by the Board’s prosecuting attorney, Mr. Hagan, and presented to the Board for its consideration. See 49 Pa.Code § 16.62(c).13 The Board convened a meeting, discussed the evidence, and determined there was sufficient cause to bring formal charges. An Order to Show Cause, triggering the formal hearing mechanism, was signed by Barbara K. Shore, Ph. D., Chairperson of the Board.
*548Once a Hearing Examiner rendered a decision pursuant to Article IX of the Health Care Services Malpractice Act, 40 P.S. §§ 1301.901-905, the matter was appealed, and the evidence was reviewed by the same Board, on a de novo basis. See 40 P.S. § 1301.905(a); 49 Pa.Code § 16.81(a) (1990). Three of the members of the Board who made the determination to prosecute Dr. Lyness went on to participate in the Board’s deliberation with respect to imposing a sanction; two of these cast votes to suspend his license permanently.14
Whether or not any actual bias existed as a result of the Board acting as both prosecutor and judge is inconsequential; the potential for bias and the appearance of non-objectivity is sufficient to create a fatal defect under the Pennsylvania Constitution. Dussia; Schlesinger Appeal; Gardner; American Bankers. Nor is the Board persuasive in analogizing this situation to that of a judge who presides at a preliminary hearing, determining that probable cause exists to hold a defendant for trial, and thereafter presides over the same defendant’s trial.15 In that situation, the defendant possesses the right to invoke his right to trial by jury, interposing a group of unbiased jurors between himself and the judge who might have heard testimony and seen evidence prior to trial that could taint his or her objectivity as an adjudicator. Under the instant scheme, however, there exists no such constitutional buffer between *549the Board as prosecutor and the Board as adjudicator. The accused is forced to face the same body which heard allegations and formed prosecutorial judgments concerning probable cause (some of it perhaps inadmissible as formal evidence), now dressed in the robe of impartial jurist. Such a schizophrenic face of justice, poses subtle dangers which threaten complete objectivity and is not permissible under the due process guaranty of the Pennsylvania Constitution, as interpreted by this Court for over three decades.16
As in Dussia, we do not here declare any statute enacted by the legislature unconstitutional. Dussia, 466 Pa. at 166, 351 A.2d at 675. Rather, the fatal defect here lies in the administrative regulations, and the loose interpretation afforded those regulations by the Board; which defect can be readily cured by placing the prosecutorial functions in a group of individuals, or entity, distinct from the Board which renders the ultimate adjudication.
In view of the constitutional infirmities in the instant case, allowing the appearance and possibility of bias, we remand this matter to the Board for further proceedings consistent with this opinion.
REVERSED AND REMANDED.
PAPADAKOS, J., files a concurring opinion.
*550McDERMOTT, J., files a dissenting opinion in which FLAHERTY, J., joins.
NIX, C.J., and LARSEN, J., did not participate in the consideration or decision of this case.