Apprehended bias in a Tribunal hearing is necessarily higher than a curial proceeding

While the threshold for apprehended bias in a Tribunal hearing is necessarily higher than a curial proceeding, and accordingly, demanded that Adama ‘be plainly confronted with matters which bear adversely to his credit’, the ‘vigorous’ approach adopted by Balthar appears to have gone beyond merely ‘test[ing] the evidence presented’. This consideration is particularly acute given the absence of legal representation, which required Balthar to take ‘care to ensure’ Adama was not ‘overborne’ by the questioning.