What is the test for an officer to prove bias?

Ontario, Canada


The following excerpt is from Jacob Securities Inc. v Typhoon Capital B.V., 2016 ONSC 604 (CanLII):

Actual bias does not have to be established. It is the existence of a reasonable apprehension of bias and not the existence of actual partiality by which bias is judged: Ghirardosi v. Minister of Highways for British Columbia, 1966 CanLII 47 (SCC), [1966] S.C.R. 367.

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