This case has obliged the court to seek to reconcile two sets of statutes which are poorly mated. One is the Street Readjustment Act (SRA) ; the other is the District of Columbia Administrative Procedure Act (DCAPA). Centrally at issue is whether a hearing on a proposal to close a street, with the applicants’ proposing to acquire title to the land on which the street is located, may reach the level of being a contested case under the DCAPA. If so, it would bring into play such basic rights as cross-examination and the opportunity for both the proponents and the opponents of the street closing to argue their positions before the members of the District of Columbia Council, which has the decisional responsibility.
The division of the court which originally heard the case decided unanimously that the street closing involved here was a contested case. Chevy Chase Citizens Association v. District of Columbia Council, D. C.App., 307 A.2d 740 (1973). That opinion was vacated by the order of the court by which we went en banc. Chevy Chase Citizens Association v. District of Columbia Council, D.C.App., 309 A.2d 97 (1973). Nonetheless, the original opinion remains a part of the reporter system, and it would be inefficient now to restate or paraphrase the analysis of the issues contained therein. We believe that the contested case question was resolved correctly in the division opinion, and we incorporate it herein by reference. Some specific comments, however, are called for by the majority opinion.
The result preferred by the majority in this case was preordained by the 5-4 decision of this court in Hotel Association of Washington, D. C. v. District of Columbia Minimum Wage and Industrial Safety Board, D.C.App., 318 A.2d 294 (1974). That case involved the minimum wage to be paid to employees in the hotel, restaurant, and allied occupations. It dealt with *320the “legal rights, duties, or privileges of specific parties”, and the Board was required to hold a hearing before determining the respective rights and duties of the affected employers and employees. D.C. Code 1973, §§ 1-1502(8), 36-407. Nonetheless, the majority of the court rejected the application of contested case concepts to that case, holding that those portions of the DCAPA were not applicable. 318 A.2d at 304 — 307. The apparent basis for that conclusion was the fact that the Act which created the Board did not itself prescribe contested case procedures. In light of that fact, it was concluded that the later-enacted DCAPA should be only partially applicable to Board proceedings.
The same type of rationale is apparent in the majority opinion in this case. Since the SRA, which was enacted in 1932, did not provide for a contested case type of proceeding (as recognized in the division’s original opinion), the majority reasons that Congress could not have intended that a street closing might come within the contested case provisions of the DCAPA, which was enacted in 1968. We disagree.
As one charts the course of the majority opinion, one is struck by an extraordinary navigational feat. Just as the majority is about to run aground on the contested case shoal, the case is split into two parts, which then narrowly pass the shoal on opposite sides. That feat, however, readily is seen to be legally defective.
The basis for our characterization may be developed on a rather succinct step-by-step basis. Consider first the DCAPA’s definition of a contested case. D.C.Code 1973, § 1-1502(8) provides that
the term “contested case” means a proceeding before the Commissioner, the Council, or any agency in which the legal rights, duties, or privileges of specific parties are required by any law . to be determined after a hearing before the Commissioner or the Council or before an agency, but shall not include (A) any matter subject to a subsequent trial of the law and the facts de novo in any court; . . .
In our view, this case fits that definition rather precisely. The owners of the property on both sides of the subject block of 44th Street submitted a proposal that the street be closed, with title to that valuable land to revert to them for their use in the development of a commercial project. In effect, the ultimate question was to become whether the land involved is to be owned by the District of Columbia and used as a street, or whether it is to be owned by private parties, “subject to such compensation therefor in money, land, or structures as the District of Columbia Council, in its judgment, may find just and equitable. ...” D.C.Code 1973, § 7-401. As we see it, issues such as title to land and compensation therefor inevitably necessitate determination of “the legal rights, duties, or privileges of specific parties”. D.C. Code 1973, § 1-1502(8). Further, unquestionably a hearing was required on the proposal to close the street. D.C.Code 1973, § 7-402. The proper consequence of the presence of these factors, as we see it: a contested case.
The majority opinion, of course, concludes to the contrary. In so doing, it discusses both the Model State Act and the federal APA. However, the DCAPA is neither of those, nor is the District of Columbia a typical geopolitical entity. In the federal APA, the dichotomy is between the quasi-legislative and the quasi-adjudicatory. Nonetheless, even under that Act, when that which normally would be legislative (or rulemaking) in nature involves a private claim to a public resource, adjudicatory standards are to be imposed in the interest of fairness. See, e. g., Sangamon Valley Television Corp. v. United States, 106 U.S.App.D.C. 30, 33, 269 F.2d 221, 224 (1959).
Our reading of the DCAPA persuades us that its basic dichotomy is between the contested case and the noncontested case. Thus, while it establishes separate procedures for rulemaking (D.C.Code 1973, §§ *3211-1505 to 1507) and contested cases (D.C. Code 1973, § 1-1509), it specifically provides that in a contested case, “the proponent of a rule or order shall have the burden of proof.” D.C.Code 1973, § 1-1509(b). That statutory provision can only be interpreted as recognizing that a proposed rule might have such “particular applicability” [see D.C.Code 1973, § 1-1502(6)] as to bring it within the purview of the contested case provisions.1
The sine qua non of the majority’s conclusion that the 44th Street proceeding did not become a contested case is a restrictive interpretation of the word “hearing” in the DCAPA. Thus, the majority opinion states: “We therefore interpret the phrase ‘after a hearing’ in the definition of ‘contested case’ to mean after a trial-type hearing where such is implicitly required by either the organic act or constitutional right.” (At 314.) Of course, if that had been the intent of Congress, it readily could have said so. It did not. To support its conclusion, the majority cites Scarlett v. Town Council, 463 P.2d 26 (Wyo.1969). The Wyoming Code’s definition of a contested case is similar to ours. See Wyo.Stat. § 9-276.19(b) (2) (1973 Cum. Supp.). However, the Scarlett case involved the expansion of a town’s boundaries. The Supreme Court of Wyoming decided that the process of political annexation does “not resolve legal rights, duties, or privileges” in the sense of affecting vested property rights. 463 P.2d at 30. We would be inclined to share that view, but we consider it indisputable that the transfer of title to valuable land from the District of Columbia to private interests does involve the rights and privileges of specific parties — both those who would acquire the land and those who want the street to remain available for transportation purposes.
Having concluded that Congress really meant “trial-type hearing” rather than “hearing” when it enacted § 1-1502(8), the majority goes on to take the step which was characterized supra. There is, of course, no question but that the Council is primarily a legislative body. The majority nonetheless recognizes that a proceeding before the Council may be a contested case, as long as it involves the immediate rights of specific parties. (At -). To escape its dilemma, the majority merely slices the case in half. The Council’s decision to close the street is labelled primarily legislative, and hence not subject to being a contested case. The Council’s concomitant responsibility to determine what compensation should be paid to the city by the abutting owners who acquire the street (which is contained in the same sentence of § 7-401 of the Code) then is acknowledged by the majority to be primarily adjudicatory in nature. That would be expected to make the case fall within the contested case category. However, having bifurcated the case, the majority is in a position to move one. Since the so-called “reverse condemnation” aspects of a street closing do entitle an “interested party” to an in rem proceeding in the Superior Court if it is dissatisfied with the Council’s compensation decision, see D.C.Code 1973, § 7-405 and Chevy Chase Citizens Association v. District of Columbia Council, supra, 307 A.2d at 749-751, the majority concludes that the latter type of proceeding would constitute “a subsequent trial of the law and the facts de novo” as described in § 1-1502(8) so as to defeat a contested case determination.
Such reasoning is manifestly faulty. The majority does not cite — nor, in our *322view, could it — any authority for the proposition that the term “de novo” may have applicability to only half of a proceeding. For a matter truly to be tried de novo, the entire proceeding must be newly at issue, not just part of it. As stated in Pittsburgh Steamship Co. v. Brown, 171 F.2d 175, 178 (7th Cir. 1948):
[PJlaintiff was entitled to a trial de novo . . . and such a trial contemplates what the term implies, a trial anew of the entire controversy, including the hearing of evidence, as though no previous action had been taken.
The device of bifurcation is, of course, indispensable to the majority’s result. If the street closing proceeding as an entity truly were subject to trial de novo in Superior Court, the decisions to be reached by the court necessarily would include whether the street should be closed. If that question thus became one for judicial determination, it scarcely could be considered legislative.2 Since the majority is unable to declare a street closing proceeding definitively to be either legislative or adjudicatory in nature, it declares it to be both, and puts each half in a different compartment. Such an approach is inconsistent with what we consider to be the basic dichotomy of the DCAPA, which is, that a matter either is a contested case or it is not.
It should be stated that the minority has no basis for quarreling with the wisdom of the Council’s decision to close 44th Street. Our concern is with the procedural aspects of the case. It appears that the reaction of the majority was motivated to a significant degree by a fear that permitting opponents of a street closing to conduct cross-examination of a proponent’s witnesses might result in an unmanageable proceeding.3 (At 316-317). We do not share that concern. It is our view that in cases such as this, elementary principles of fairness and the public interest are furthered by an appropriate development of both sides of an issue, through both cross-examination and argument before the decision-makers.
We noted at the outset that the SRA and the DCAPA mesh poorly. This circumstance exists to varying degrees with respect to each of the many Acts which have created various agencies for the District of Columbia. As would be expected, Congress recognized this fact when it enacted the DCAPA. The first section of that Act accordingly provides (D.C.Code 1973, § 1-1501):
This chapter shall supplement all other provisions of law establishing procedures to be observed by the Commissioner, the Council, and agencies of the District government in the application of laws administered by them, except that this chapter shall supersede any such law and procedure to the extent of any conflict therewith.
That statute was considered by this court in Wallace v. District Unemployment Compensation Board, D.C.App., 289 A.2d 885 (1972). The unanimous opinion in that case was written by the author of the majority opinion in this case. With reference to § 1-1501, the court then stated (at 887):
This language is clear, unambiguous and unequivocal. Any procedures of the Board which do not comply with the APA are superseded.
We consider the fact that the Street Readjustment Act of 1932 did not provide for a contested case type of proceeding to be legally irrelevant in light of the provisions of the DCAPA, which was enacted 36 years later. A hearing was required in this case, and it did determine “the legal rights, duties, or privileges of specific par*323ties”. D.C.Code 1973, § 1-1502(8). By definition, as we see it, that made the proceeding a contested case, which should have brought into play the full procedural guarantees of § 1-1509.
In concluding, one fact should he stressed. The final word of the majority opinion is “DismissedThe Council’s action is not affirmed by the majority on its merits; it is declared unreviewable. We consider such a result to be inconsistent with the basic philosophies of both the DCAPA and that section of the District of Columbia Court Reorganization Act of 1970 which restated the jurisdiction of this court to review actions of a number of agencies, specifically including the District of Columbia Council.4 : D.C.Code 1973, § 11-722. In effect, the majority is saying that it does not want to carry this particular ball, and is handing it back to Congress. The problem, erroneously in our opinion, thus now rests again with the legislature. We respectfully dissent.
. No one has taken the position that a street closing is rulemaking. The majority opinion stresses the concept that “rulemaking and adjudication are different processes requiring different procedures.” (At 314.) If the majority perceives that to be the .basic dichotomy in the DCAPA, and assuming this case not to involve rulemaking, it is difficult to understand how the majority can treat the question of title to the land involved as not being adjudicatory in nature —particularly since they concede that the question of the compensation for the land is adjudicatory.
. The reverse condemnation statute itself makes it clear that only “damages and benefits” are to be determined in such a proceeding. D.C.Code 1973, § 7-405.
. The same type of thinking also appears to have influenced the majority in Hotel Ass’n of Washington, D. C. v. District of Columbia Min. Wage & Indus. Safety Bd., supra.
. The majority obviously has misgivings as to insulating this type of Council action from normal judicial review, noting that “equitable relief” from a street closing may be sought in the Superior Court. (At 317, n. 18.) We are at a loss to understand the rationale for denying direct review under the DCAPA while encouraging the seeking of some undefined remedy in the trial court. Presumably any action taken by the trial court would be reviewable here, so perhaps the principal effect of the majority opinion will be to interject another layer of judicial proceedings.