What is the test for bias in the management of public business?

Alberta, Canada


The following excerpt is from Casson v. Reed, 1974 CanLII 310 (AB QB):

The principles which govern the conduct of persons engaged in the management of public business have been expressed by many jurists over the years. The real test is whether there exists bias or the likelihood of bias in favour of the respondent's personal interest which may have influenced his vote. Moreover, neither his motives nor the extent of his interest is to be taken into account. The mere existence of a pecuniary interest raises a presumption of bias: Wanamaker v. Petterson, supra; Rex v. Sunderland Justices, [1901] 2 K.B. 357 at 371. The respondent's pecuniary interest is apparent on the bare facts. One does not have to speculate to find it.

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