The bias rule demands that the decision maker should be disinterested and/or
unbiased in the matter to be decided. Justice should not only be done but be seen to
be done. If fair minded people would reasonably apprehend/suspect the decision
maker has prejudged the matter, the rule is breached (often referred to as ‘a
reasonable apprehension of bias’). The application of the bias rule is most easily
established when the person who is the position of accuser also is the decision
maker or participates in the investigation/decision or gives advice throughout the
course of the matter. This is not a hard and fast rule and will depend to a large
extent on the circumstances of a matter.