Bias: reasonable apprehension of impartiality bars decisions when circumstances create a real likelihood of prejudice.

The doctrine of bias invalidates action where there is a reasonable possibility that a decision maker is predisposed against a party. Three forms-subject matter, pecuniary and personal-are recognised; courts apply a fact sensitive test of real likelihood or reasonable apprehension evaluated from the viewpoint of a reasonable informed person, requiring cogent positive evidence rather than conjecture.

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