Recusal and apparent bias: connected rulings, interim observations, and remote allegations were held insufficient to show reasonable apprehension.

A recusal request was tested against the fair-minded and informed observer standard, rather than the litigants' subjective unease. Prima facie observations in an interim order, advance service on defence counsel, and interim protection against remarks and departmental action were held insufficient, by themselves, to show pre-judgment or bias. Earlier rulings in connected PMLA matters were confined to the issues then decided and did not create a disqualifying predisposition. Allegations based on political association, public statements, or relatives' professional links were found too remote and speculative to establish a real conflict of interest. Expeditious listing and prior adverse rulings, without more, were also held inadequate for recusal.

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Issues: Whether the recusal applicants established a reasonable and legally sustainable apprehension of bias on the basis of the order dated 09.03.2026, earlier judicial observations in connected matters, the expeditious listing of the case, alleged ideological association, alleged conflict of interest arising from relatives' professional engagements, and other related circumstances.

Analysis: The grounds urged for recusal were examined against the settled test of a fair-minded and informed observer and not the subjective unease of a litigant. The order dated 09.03.2026 contained only prima facie observations made at an interim stage and could not, by itself, establish pre-judgment or bias. Service on counsel who had represented the accused before the Trial Court was treated as valid advance service in the circumstances, and the stay of remarks and consequential departmental action against the Investigating Officer was held to be a normal interim protection. Earlier detailed judgments in matters arising from the same dispute, including challenges relating to arrest and bail under the Prevention of Money Laundering Act, 2002, were confined to the statutory tests then in issue and did not create a disqualifying predisposition for later proceedings. Allegations based on attendance at legal programmes, public statements by a political functionary, or professional engagements of relatives were found too remote and speculative to establish a real conflict of interest or reasonable apprehension of bias. The Court also held that expeditious hearing in MP/MLA matters and adverse rulings in earlier cases do not, without more, furnish a ground for recusal.

Conclusion: The applicants failed to establish any real or reasonable apprehension of bias, and the request for recusal was rejected.

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