Rule Against Bias bars a tribunal member from hearing appeals over his own earlier decision.

The rule against bias is part of natural justice and requires that no person sit in review of his own prior decision. It applies to judicial, quasi-judicial and administrative proceedings, and a decision-making process is vitiated where the same authority later hears an appeal over an earlier order made by him, even without proof of personal bias. On that basis, an Accounts Member who had decided the petitioner's first appeals in the same matter was disqualified from hearing the second appeals, and the tribunal order was held unsustainable and liable to be quashed.

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Issues: Whether the Accounts Member of the Tribunal was disqualified from hearing the second appeals because he had earlier decided the petitioner's first appeals in the same matter.

Analysis: The rule against bias forms part of natural justice and embodies the principle that no one should be a judge in his own cause. The requirement applies to judicial, quasi-judicial, and administrative proceedings. Where the same authority later sits in appeal over its own prior decision, the decision-making process is vitiated even in the absence of personal bias, because fair play and judicial discipline require abstention. The earlier appellate orders had been made by the same officer who later heard the second appeals as a Tribunal Member, so he was placed in the position of reviewing his own decision.

Conclusion: The Member was disqualified to hear the second appeals, and the impugned tribunal order was unsustainable and liable to be quashed.

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