A STUDY ON THE DOCTRINE OF REAL

LIKELIHOOD OF BIAS IN THE CONTEXT OF

ADMINISTRATIVE DECISIONS.

UNDERGRADUATE PROJECT ON ADMINISTRATIVE LAW

Submitted by
BUVANIYAA SRI L
Reg. No: BC0220009

Submitted to
Mr Jino Kurian

TAMIL NADU NATIONAL LAW UNIVERSITY

(A State University Established by Act No. 9 of 2012)
Tiruchirappalli, Tamil Nadu — 620 009
India

1
 ACKNOWLEDGEMENTS

I am deeply elated and indebted to acknowledge my heartfelt thanks to assistant

professor Jino Kurian, Assistant Professor of Law, and Professor V Nagaraj, the esteemed
Vice Chancellor of my University. Their great patience, unwavering support, remarkable
guidance and encouragement afforded me the opportunity to work on a project of great
significance titled "A Study on the Doctrine of Real Likelihood of Bias in the Context of
Administrative Decisions" I gained and learnt meticulous planning taking care of minute
details and desire to excel that has enriched my understanding of a diverse array of subjects
and sharpened my research skills.

I am grateful to remember their mentorship and the invaluable insights they provided
throughout this endeavour. Also, I extend my whole hearted thanks to my parents and friends
without whose unwavering support and encouragement the successful completion of this
assignment within the stipulated time frame would not be possible. This project would not
have been as rewarding without their steadfast assistance and belief in my capabilities. I wish
to express my thanks to all the staff members and my fellow students for their constant
guidance and inspiration.

2
 DECLARATION

I, “Buvaniyaa Sri L”, bearing registration number “BC0220009” and currently

studying second year B.Com LLB., at “Tamil Nadu National Law University”, do hereby
solemnly declare that the research paper/project titled "A Study on the Doctrine of Real
Likelihood of Bias in the Context of Administrative Decisions" is a product of my individual
effort under the meticulous guidance and remarkable supervision of “Mr Jino Kurian”,
Assistant Professor of Law at “Tamil Nadu National Law University,
Tiruchirappalli-620009”.

I affirm that this work, in its entirety, is the result of my diligent and conscientious
research, with no prior publication or credit granted by any other university or academic
institution for any degree or diploma program. This declaration stands as a testament to the
originality and authenticity of my efforts in conducting this research paper/project. It is my
sincere endeavour to contribute meaningfully to the field of legal scholarship, and I am
grateful for the guidance and support provided by Prof Jino Kurian throughout this journey.

Date: 15th April 2024

Place: Tiruchirappalli

3
 THE TABLE OF CONTENTS

LIST OF AUTHORITIES....................................................................................................... 5
Case Laws............................................................................................................................ 5
INTRODUCTION.................................................................................................................... 6
Statement of the Problem..................................................................................................... 6
Objectives of the Research................................................................................................... 7
Questions of the Research.................................................................................................... 7
Methodology of the Research.............................................................................................. 7
Review of Literature.............................................................................................................8
Limitations of the Research..................................................................................................9
CHAPTER 1: THEORETICAL FRAMEWORK.............................................................. 10
Real Likelihood of Bias......................................................................................................10
Test of Real Likelihood of Bias..........................................................................................12
CHAPTER 2: SUBJECTIVE AND INCONSISTENT NATURE OF THE PRINCIPLE..
13
THE CONCLUSION............................................................................................................. 15
BIBLIOGRAPHY....................................................................................................................16

Journal Articles.................................................................................................................. 16
Books..................................................................................................................................16
Online Sources................................................................................................................... 16
Case Laws.......................................................................................................................... 17

4
 LIST OF AUTHORITIES

Case Laws

1. R v Rand (1866) LR 1 QB 230 at 233

2. R. v. Sunderland Justices [2000] EWHC J1114-7
3. R. v. Barnsley Licensing Justices [1960] EWCA Civ J0518-1
4. R v Essex Justices, ex parte Perkins [1927] 2 KB 475
5. Cottle v. Cottle 129 W. Va. 344
6. In Re Ong Eng Guan's Application (1959) 25 M.L.J. 92
7. In Re Chua Ho Ann G.R. No. 128222. June 17, 1999
8. A. K. Kraipak v. Union of India AIR 1970 SC 150
9. Dimes v. Grand Junction Canal & Co 1852, H. of Lords
10. Jeejeebhoy v. Asst. Collector of Thane AIR 1965 SC 1096

5
INTRODUCTION

Administrative decisions refer t those actions, ruling and decisions that are taken by
an administrative body within the executive organ of the government. The law specifies their
composition. They are usually comprised of administrative boards, tribunals, commissions or
individual officers. Administrative functions are delegated to these bodies and some
administrative decisions are taken in the course of performing these functions. The rule of
law is closely followed by making sure that the principles of fairness, transparency and
accountability are upheld. The real likelihood of bias is a doctrine that aids in ensuring that
these are upheld and prevent partial decisions. In A. K. Kraipak v Union of India1, the court
held that there was a personal bias in the administrative proceedings.
Bias refers to a systematic perception towards particular beliefs, views, actions or
perspectives2. Bias can arise from various sources such as personal experiences, stereotypes,
cultural norms, institutional structures, etc. It can manifest in different forms depending on
the context and often impairs fairness in decisions and judgements. This project aims to study
the subjective nature of the doctrine of real likelihood of bias as it raises concerns about the
reliability of administrative decisions. To substantiate this argument, the project focuses on
achieving the following objectives.
Firstly, a comprehensive understanding of the doctrine of real likelihood of bias is
established. Secondly, the factors and criteria that are used to assess bias within proceedings
are analysed. Thirdly, the influence of the subjective nature of the doctrine is examined.
Fourthly, the impact of inconsistent application of the doctrine is assessed.
The outcome of this project will shed clarity on how the doctrine of real likelihood of
bias is applied in the administrative decision making process.

Statement of the Problem

In administrative law, the principle of real likelihood of bias ensures that judicial
fairness is upheld; however, the subjective nature of bias assessment raises concerns about
the reliability and objectivity of administrative decisions.

1
[AIR 1970 SC 150]
2
Cambridge Dictionary, 'Bias' https://dictionary.cambridge.org/dictionary/english/bias accessed 16 April 2024.

6
Objectives of the Research

1. Establish a sound understanding of the doctrine of real likelihood of bias in the

context of administrative law.
2. Identify and analyse the factors and criteria used in the assessment of likelihood of
bias in court proceedings.
3. Analyse the influence of the subjective nature of assessment of likelihood of bias on
the objectivity of decisions.
4. Analyse the impact of inconsistent application of the doctrine in court proceedings.

Questions of the Research

1. What is the doctrine of real likelihood of bias?

2. What is the intent behind the application of the doctrine?
3. When can this principle be invoked by the court?
4. What are some key factors in assessing bias within proceedings?
5. What is the test of bias?
6. Whether the principle of real likelihood of bias gives rise to any inconsistencies or
ambiguity?
7. What is the influence of the subjectivity of this principle in administrative decisions?
8. What is the impact of the inconsistent application of the principle of real likelihood of
bias?

Methodology of the Research

The project studies the principle of Real Likelihood of Bias. Therefore, it requires the
utilisation of provisions from the Constitution of India, 1949, precedents set by the Courts,
books, journal articles, online sources and statistics from private organisations”. No primary
data has been used in this research. Only data collected from secondary resources have been
used in this project. “Occasionally, judgements, articles and statutes from foreign countries,
which follow the common law system, have been used for their persuasive value”. These are
only for their persuasive value and do not contain any authority or precedent in India.
Therefore, the project uses the doctrinal method of research.

7
Review of Literature

1. Lionel Leo & Siyuan Chen, Reasonable Suspicion or Real Likelihood: A

Question of Semantics? Re Shankar Alan s/o Anant Kulkarni, 2008 S'pore J.
Legal Stud. 446 (2008).
The journal article "Reasonable Suspicion or Real Likelihood: A Question of
Semantics" compares the test of reasonable suspicion of bias with the test of real
likelihood of bias. The article uses the High Court case of Re Shankar Alan s/o Anant
Kulkarni in particular for the comparison. It focuses on how stringent these two tests
are and how these tests are applied. The article also explores whether these tests or
substantive or merely semantic. While taking a legal decision, the authors suggest that
a pragmatic approach be taken, which prioritises all acts and circumstances and
excludes individual biases.
2. Rahul Kanna R.N., Nature and Evolution of Rule Against Bias Under Indian
Administrative Law Jurisprudence, 1 Juscholars J. 26 (2019).
The journal article titled "Nature and Evolution of Rule Against Bias Under
Indian Administrative Law Jurisprudence" is authored by Rahul Kanna R.N. The
article talks about the modern jurisprudence of natural justice under Indian
administrative law. The article especially focuses on the rule against bias.The article
also gives information on the evolution of the said principle in the Indian courts by
analysing cases. It explores the application of the test of real-likelihood of bias in
dealing with apparent bias. It also talks about the 'Doctrine of Necessity', which is an
exception. The article’s analysis also evaluates the adaptation of the test of
real-likelihood of bias test. The article also suggests solutions for a flexible approach
towards the appication of the test. The article concludes with an emphasis on the
importance of maintaining public trust in the justice system. The need for a balanced
approach in addressing bias in administrative and quasi-judicial decisions is urgent.
3. "Principles of Natural Justice." In Legal Document. Page 1-268.
The article titled "Principles of Natural Justice" discusses various aspects
concerning natural justice principles. These principles act as a check on the arbitrary
exercise of State power in order to deliver justice for citizens. The document
emphasises some key principles, that include the importance of justice being seen to
be done by those involved in the process and unbiased impartial hearings. Others
include: the necessity of a speaking order, the requirement for a show cause notice,

8
 audi alterum partem, the significance of cross-examination, and the need for a
reasoned decision. It also emphasises that failing to follow to principles of natural
justice may make an order void or voidable, based on the facts and circumstances.
4. Rajasingham, Sanjayan. "Reforming the Rule Against Bias in Administrative
Law." CALQ (2017) Vol. 3.3: 28-33.
The article titled "Reforming the Rule Against Bias in Administrative Law."
by Sanjayan Rajasingham analysis the uncertainties surrounding the test for likelihood
bias. The article compares the real likelihood test and the reasonable suspicion test.
The article suggests that there is balance between efficiency and public confidence in
the administration of justice, which should be protected. The author suggests an
approach that takes the context into consideration. It suggests for using the reasonable
suspicion test in some cases to promote public confidence and real likelihood of bias
in some cases to improve efficiency. The paper emphasises the importance of legal
certainty to maintain credibility and public trust.
5. A. K. Srivastava, “Doctrine of Legitimate Expectation”, J.T.R.I. Journal, 1
J.T.R.I.J 2 (1995).
The journal article "Doctrine of 'Legitimate Expectation'" by A. K. Srivastava
discusses the concept of legitimate expectation. It talks about how legitimate
expectation is a doctrine developed by courts to review administrative actions. The
article also emphasises on the importance of fair treatment by administrative
authorities. The article explains that legitimate expectation does not always lead to
enforceable rights. According to the article, it plays a role in ensuring procedural
fairness. It also mentions about the connection between legitimate expectation and the
right to be heard. Additionally, the article analyses whether there is a relation between
legitimate expectation and Article 14 of the Constitution of India.

Limitations of the Research

A considerable number of the reviewed papers are from international sources.

However, care has been taken that the case laws used from these sources follow the common
law system. They do not hold any authoritative value and have only been used for their
persuasive value.

9
CHAPTER 1: THEORETICAL FRAMEWORK

Real Likelihood of Bias

In administrative decisions the real likelihood of bias refers to the examination of

whether any actual risks that bias may have influenced the decision making process. The
actual bias involves proof of partiality, prejudice or inherent belief whereas the real likelihood
of bias revolves about the perspective on impartiality and fairness from the standpoint of a
Lay man3. Various factors are evaluated in this assessment which includes the decision
makers’ conduct, the decisions context, the existence of conflicts of interest and the
Indicators of biasedness4. To endorse the concept of transparency, accountability and fairness
and reduce the risk of bias some safeguards in the procedure are taken such as disclosure
requirements. In R v. Rand5, Blackburn J. stated that the court could intervene if there is a real
likelihood or genuine bias present in the case in the opinion of the judge. This was further
upheld in subsequent cases.

The protection of the integrity of the decision making process of the administrative
body and securing the confidence of the public in impartiality and fairness of government
actions is the aim behind the utilisation of bias doctrine6. The doctrine addresses the actual
bias and also the perception of bias from an objective standpoint. And hence the doctrine of
real likelihood intends to endorse the concept of fairness in procedure, accountability and
transparency in administration. In Dimes v. Grand Junction Canal and Co.7, the House of
Lords held that there was a pecuniary bias on the part of the L. C. as he was a shareholder of
the Canal company. To evaluate the fairness and impartiality of decision-making processes,
the doctrine provides a framework. In this, the doctrine takes into account both objective
criteria and subjective factors, such as conflicts of interest / indicators of partiality and the
conduct of decision-makers respectively.

When a party in the case alleges that bias has influenced or could influence the result
of a decision to an administrative proceeding, the doctrine can be invoked in court. When a
judge examines the legality and fair decision of the administrative body, this invocation

3
F. A. Trindade, The Proper Test of A Real Likelihood of Bias: R. v. Abingdon Justices, ex p. Cousins, 7
MALAYA LAW REVIEW 170 (1965).
4
Rule Against Bias, Umashankar Dhakar, 2022, IJCRT 2201525, 10 IJCRT 665 (2022)
5
(1866) LR 1 QB 230 at 233
6
Rajasingham, Sanjayan. "Reforming the Rule Against Bias in Administrative Law." CALQ (2017) Vol. 3.3:
28-33.
7
1852, H. of Lords

10
occurs in the judicial review. The jurisdiction and the nature of the proceedings of the
administrative body may affect the threshold for invoking the doctrine. Some situations in
which the Doctrine of real likelihood of bias can be invoked are given below.
a). Actual bias
When there is a circumstance in which there is evidence that the decision maker has
personal interest or prejudice in the results of the case such as personal enemy or
financial gain from the party involved in the case.
b). Apprehension of bias
When there is a suspicion or reasonable apprehension for the existence of bias the
Doctrine may be invoked even in the absence of actual bias. Prior interactions
between the party and the decision maker, statements from the public which indicate
biasedness or conflict of interest are some factors in the circumstances8.
c). Failure to act impartially
The decision maker may disregard relevant evidence and show favouritism or conduct
proceedings in a manner that undermines the principles of fairness. Here the decision
maker fails to act impartially in the conduct of proceedings.
d). Breach of natural justice
In a decision-making process, sometimes the right to a fair hearing or right to an
unbiased decision maker may be breached. Here the principle of natural justice is
breached and to challenge the validity of the decision, the doctrine may be invoked9.

In Jeejeebhoy v. Assistant Collector of Thane10, the Bench was reconstituted on the

ground that one of the judges was a member of the cooperative society for which the land in
dispute was acquired. Judges may intervene to review administrative decisions in such cases.
They may quash the decision if bias is influenced in the outcome and may order to rehear the
case before a different body to achieve the goal of having public confidence in the
governmental processes. Some factors considered to assess whether bias has influenced or
could influence the results are:
1. Conduct of decision makers which may indicate favouritism and hostility towards
a party11.
8
F. A. Trindade, The Proper Test of A Real Likelihood of Bias: R. v. Abingdon Justices, ex p. Cousins, 7
MALAYA LAW REVIEW 170 (1965).
9
Rule Against Bias, Umashankar Dhakar, 2022, IJCRT 2201525, 10 IJCRT 665 (2022)
10
AIR 1965 SC 1096
11
Rajasingham, Sanjayan. "Reforming the Rule Against Bias in Administrative Law." CALQ (2017) Vol. 3.3:
28-33.

11
 2. Prior relationships or interactions which may include personal, professional or
financial connections and may indicate potential bias.
3. Context of the decision which may involve contentious issues increasing the
likelihood of bias.
4. Conflicts of interest must be examined for financial interests, affiliations with
parties involved or personal bias.
5. Adherence to procedural fairness Such as providing opportunities to be heard and
considering all relevant evidence.
6. Public statements or behaviour that may indicate bias or prejudice of the decision
maker.

Test of Real Likelihood of Bias

The test of bias is a legal standard which is useful to assess probability / a real risk
that bias has influenced or could influence the decision of the administrative body. The test
involves the evaluation of the circumstances of the decision-making process from the
perspective of a reasonable / objective observer12.
One of the key elements of the test is the perception of an objective observer. The
proceeding should be fair and unbiased in his perception. Secondly, there should be a genuine
risk of bias. This requires careful consideration of the facts and circumstances. Lastly,
objectivity in the evaluation of the facts of the case is vital to uphold the fairness of the
decision.

12
Rahul Kanna R.N., Nature and Evolution of Rule Against Bias Under Indian Administrative Law
Jurisprudence, 1 Juscholars J. 26 (2019).

12
CHAPTER 2: SUBJECTIVE AND INCONSISTENT NATURE OF THE
PRINCIPLE

The doctrine of real likelihood of bias faces challenges and inconsistencies in its
application as it is riddled with inconsistencies and ambiguities. The subjectivity in its
assessment is one of the primary challenges the doctrine faces. Determining whether it is just
a probability of bias or whether a genuine risk of bias is involved makes the doctrine highly
subjective13. It can often result in inconsistencies in the application of the doctrine across
various cases.
The subjectivity inherent in this doctrine highly influences the decision of the Court.
The subjective nature of the bias assessment causes different judges to interpret the doctrine
differently. This reduces the predictability of the case and erodes the faith of the public in the
court. This subjectivity can create challenges for the decision makers themselves14. They
must take complex issues and factual circumstances into consideration before passing a
judgement. They must also navigate through their own biases. This creates difficulty in
passing fair decisions. The subjectivity of assessment also affects the effectiveness of
safeguards against bias. In Cottle v. Cottle15, Sir Boyd Merriman stated that even if the court
was satisfied that there were no actual biases, a reasonable impression that the hearing may
be biassed is sufficient.
In Re Ong Eng Guan16, Rose C. J. stated that the reasonable suspicion of the involved
party for the likelihood of bias is not sufficient. He emphasised that the court itself should be
satisfied with the likelihood. Similarly, in a case17, Buttrose J. did not analyse whether there
was a likelihood of bias in the perspective of a reasonable man or involved person18. Instead,
he chose to apply a more stringent test. These three cases show how the subjectivity of the
doctrine of reasonable likelihood of bias can pose challenges in application of the doctrine
and how it may lead to conflicting views among the judges.
Moreover, the doctrine lacks clear, codified criteria19. There is no standard set for
judging the likelihood of bias. Generally, the conduct of the decision makers and the presence

13
A. K. Srivastava, “Doctrine of Legitimate Expectation”, J.T.R.I. Journal, 1 J.T.R.I.J 2 (1995).
14
F. A. Trindade, The Proper Test of A Real Likelihood of Bias: R. v. Abingdon Justices, ex p. Cousins, 7
MALAYA LAW REVIEW 170 (1965).
15
Cottle v. Cottle 129 W. Va. 344
16
(1959) 25 M.L.J. 92
17
In Re Chua Ho Ann G.R. No. 128222. June 17, 1999
18
L. W. Athulathmudali, 'Re Chua Ho Ann — A Reply' (1963) 5(2) Malaya Law Review 399.
19
Rahul Kanna R.N., Nature and Evolution of Rule Against Bias Under Indian Administrative Law
Jurisprudence, 1 Juscholars J. 26 (2019).

13
of conflict in the interests of the parties are taken into consideration. However, there is no
Universally accepted framework for the evaluation. The cases are judged based on precedents
and the reasoning of the judges, which is subjective. This over-reliance on precedents is
another challenge involved. This leads to the application of precedents stringently without
taking the unique facts of each case into consideration.
Some decision makers may be reluctant to address the bias present in their own
institutions20. Even when the bias is identified, the remedies that can be provided are
limited21. The only remedy in most cases is a request for rehearing or reconsideration or the
court may ask to change the decision making panel. This may not fully address the concerns
of the parties involved and only cause more delays and costs. These inconsistencies are
further elaborated using the following cases.
In R v. Sunderland Justices22, the decisions of justices were challenged. In such cases,
it is assessed whether there was any genuine likelihood of bias on the judges’ part. The case
follows the test set forth in R v. Rand. This case focused on the factual determination of
whether there was any genuine likelihood. This laid the groundwork for future cases. This
reinforced that proving the actual presence of bias is not mandatory. It is enough to
demonstrate a real likelihood.
In R v. Barnsley23, Lord Evershed M. R. suggested an objective test as the precedent in
R v. Rand followed while Devlin L. J. asserted a more stringent test. Devlin L. J. stated that
the court must satisfy itself that there was a real likelihood of bias based on the factual
impression of the case. This shows how the judges may have conflicting or divergent views
on the level of stringency or scrutiny. This poses a challenge in applying this doctrine.
In R v. Essex Justices, ex parte Perkins24, Avory J. emphasised that the justice should
be administered in such a way that it satisfies reasonable persons that the tribunal was
impartial. Swift J. also emphasised that the decision must be perceived as impartial and
unbiased by all those involved in the proceedings. Here, the judges have focused on a
reasonable impression or satisfaction of a man of sound and reasonable mind. Here, the court
did not require proof of actual bias.
In the three cases above, each of the judges had varying opinions. In R v. Sunderland
Justices, the court was satisfied with a demonstration of reasonable likelihood of bias. Devlin
20
A. K. Srivastava, “Doctrine of Legitimate Expectation”, J.T.R.I. Journal, 1 J.T.R.I.J 2 (1995).
21
Lionel Leo & Siyuan Chen, Reasonable Suspicion or Real Likelihood: A Question of Semantics Re Shankar
Alan s/o Anant Kulkarni, 2008 S'pore J. Legal Stud. 446 (2008).
22
[2000] EWHC J1114-7
23
[1960] EWCA Civ J0518-1
24
[1927] 2 KB 475

14
L. J. asserted that the court should be satisfied that there was real bias while Avory J. and
Swift J. emphasised on reasonable impressions of the persons involved or any reasonable
man.
The impact of this inconsistency in the doctrine has significant consequences on the
decision making processes of the administrative bodies. The decisions may seem arbitrary
and partial. It undermines fairness and impartiality and erodes the confidence of the
individuals on the decision making body. It increases the litigation as parties challenge the
decisions under the perception of bias. It leads to delays in the overall functions of the
administrative bodies. It poses challenges to transparency and accountability of the persons
involved. The decision makers may avoid scrutiny for their decisions25. The inconsistency
also leads to confusion and uncertainty as the public will not be able to understand rights,
duties and obligations.

THE CONCLUSION

The inherent challenges and inconsistencies in the application of doctrine of real

likelihood of bias in a decision making process are discussed in detail. These inconsistencies
stem from the subjective nature of the assessment of the bias. The clear lack of criteria and
the power of the judge to interpret the doctrine in his own way pose even more challenges.
This erodes fairness, impartiality, and public confidence in governmental actions. These
consequences include: delays, challenges to transparency and accountability, and increased
litigation. Addressing these challenges requires careful consideration of the underlying
factors influencing bias assessment and the development of more objective criteria to uphold
the principles of fairness and justice in administrative proceedings.

25
Lionel Leo & Siyuan Chen, Reasonable Suspicion or Real Likelihood: A Question of Semantics Re Shankar
Alan s/o Anant Kulkarni, 2008 S'pore J. Legal Stud. 446 (2008).

15
 BIBLIOGRAPHY

Journal Articles

1. Lionel Leo & Siyuan Chen, Reasonable Suspicion or Real Likelihood: A Question of
Semantics Re Shankar Alan s/o Anant Kulkarni, 2008 S'pore J. Legal Stud. 446
(2008).
2. A. K. Srivastava, “Doctrine of Legitimate Expectation”, J.T.R.I. Journal, 1 J.T.R.I.J 2
(1995).
3. Rajasingham, Sanjayan. "Reforming the Rule Against Bias in Administrative Law."
CALQ (2017) Vol. 3.3: 28-33.
4. Rahul Kanna R.N., Nature and Evolution of Rule Against Bias Under Indian
Administrative Law Jurisprudence, 1 Juscholars J. 26 (2019).
5. F. A. Trindade, The Proper Test of A Real Likelihood of Bias: R. v. Abingdon
Justices, ex p. Cousins, 7 MALAYA LAW REVIEW 170 (1965).
6. L. W. Athulathmudali, 'Re Chua Ho Ann — A Reply' (1963) 5(2) Malaya Law
Review 399.
7. Rule Against Bias, Umashankar Dhakar, 2022, IJCRT 2201525, 10 IJCRT 665 (2022)

Books

1. "Principles of Natural Justice." In Legal Document. Page 1-268.

2. William F. Fox, Jr., Understanding Administrative Law (4th ed., 2000).

Online Sources

1. Cambridge Dictionary, 'Bias' https://dictionary.cambridge.org/dictionary/english/bias

accessed 16 April 2024.
2. Live Law, 'Party Alleging Bias Need to Show Only Reasonable Likelihood of its
Existence and Not Absolute Proof: Delhi HC' (11 April 2024)
https://www.livelaw.in/news-updates/party-alleging-bias-need-to-show-only-reasonab

16
 le-likelihood-of-its-existence-and-not-absolute-proof-delhi-hc-150432?infinitescroll=
1 accessed 16 April 2024.
3. Law Bhoomi, 'Rule Against Bias' https://lawbhoomi.com/rule-against-bias/ accessed
16 April 2024.
4. Advocate Tanmoy, 'Real Likelihood Test' (5 February 2021)
https://advocatetanmoy.com/2021/02/05/real-likelihood-test/ accessed 16 April 2024.
5. Lawyers Club India, 'Test of Real Likelihood of Bias or Reasonable Suspicion of
Bias'
https://www.lawyersclubindia.com/articles/test-of-real-likelihood-of-bias-or-reasonabl
e-suspicion-of-bias-3577.asp accessed 16 April 2024.

Case Laws

1. R v Rand (1866) LR 1 QB 230 at 233

2. R. v. Sunderland Justices [2000] EWHC J1114-7
3. R. v. Barnsley Licensing Justices [1960] EWCA Civ J0518-1
4. R v Essex Justices, ex parte Perkins [1927] 2 KB 475
5. Cottle v. Cottle 129 W. Va. 344
6. In Re Ong Eng Guan's Application (1959) 25 M.L.J. 92
7. In Re Chua Ho Ann G.R. No. 128222. June 17, 1999
8. A. K. Kraipak v. Union of India AIR 1970 SC 150
9. Dimes v. Grand Junction Canal & Co 1852, H. of Lords
10. Jeejeebhoy v. Asst. Collector of Thane AIR 1965 SC 1096

17