It is well settled that every member of a tribunal called upon to try issues in judicial or quasi-judicial proceedings must be able to act judicially. It is essential for judicial decisions and judicial administration that judges act impartially, objectively, and without any bias.

In such cases, the test is not whether bias has actually affected the judgment; rather, the test always revolves around whether a litigant could reasonably apprehend bias attributable to a member of the tribunal. It is in this sense that it is often said that justice must not only be done but must also appear to have been done.

When dealing with cases of bias attributed to members constituting tribunals, it is necessary to distinguish between pecuniary interest and other forms of prejudice. Pecuniary interest, no matter how small, in the subject matter of the proceedings would wholly disqualify a member from acting as a judge.

However, where bias, apart from pecuniary interest, is suggested, it often becomes necessary to consider whether there is a reasonable ground for assuming the possibility of bias and whether it is likely to create reasonable doubt in the minds of litigants or the public at large regarding the fairness of the administration of justice.

Ultimately, this remains a question of fact to be decided in each case (Manaklal AIR 1957 SC 425).