Reasonable apprehension of bias and waiver barred challenge to selection committee recommendation, with statutory remedies still pending.

A challenge to a Selection Committee recommendation was barred by waiver where the appellant knew the relevant facts but participated in the interview without objecting to the committee's constitution. The governing bias test remained whether there was a reasonable apprehension of bias, not proof of actual bias, and bias in a selection process may affect deliberations subtly. The writ challenge was also premature because further statutory scrutiny and other remedies were still available, so the recommendation had not yet attained final effect. The challenge therefore failed and the writ petition and appeal were not maintainable at that stage.

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Issues: Whether the challenge to the Selection Committee's recommendation was barred by waiver and was otherwise not maintainable in view of the availability of further statutory remedies, and whether bias in the committee could be successfully alleged in the circumstances.

Analysis: The governing principle is that a member of a quasi-judicial or administrative body must be free from bias, and the test is whether there is a reasonable ground for apprehending likelihood of bias, not proof of actual bias. In the setting of a selection board, such bias may influence deliberations in a subtle manner. However, where the appellant knew the relevant facts yet participated in the interview without objecting to the committee's constitution, the challenge is barred by waiver. The existence of further scrutiny by the Executive Council and other statutory remedies also shows that the writ challenge was premature and that the recommendation had not yet attained final effect.

Conclusion: The challenge failed. The appellant was held to have waived the objection to the committee's constitution, and the writ petition and appeal were not maintainable at that stage.

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