b) Decision not announced in oral proceedings 

The decision under review in T 2020/20 had been signed by persons who did not constitute the examining division holding the oral proceedings. The board declared the decision to be null and void. It argued inter alia that it was irrelevant that the new Chair, after having studied the written file, had arrived at the same opinion as that expressed in the minutes of the oral proceedings. Furthermore, the board held that it was also irrelevant to the finding of a substantial procedural violation that the examining division in its former composition had not announced its decision in the oral proceedings (see also T 862/98).