ABSTRACT
The second rule of procedural fairness is the so called ‘bias rule’, the Latin term for which is nemo debet esse judex in propria causa, that is, no one can be judge in his or her own cause.
In R v Sussex Justices ex p McCarthy (1924), Lord Hewart CJ stated that it was ‘of fundamental importance that justice should not only be done, but should manifestly and undoubtedly be seen to be done’.
