A newspaper headline must be read in context with the accompanying article to determine whether it constitutes a recommendation or direction by the newspaper to a judge or merely reports a third party's views. The nature of the proceedings (here, a non-adversarial statutory review where the judge was not bound by the rules of evidence) is relevant to assessing whether publication gives rise to a serious risk that the court would appear not to have been free from extraneous influence. The status and influence of the person whose views are published is also a relevant factor.
The full text is available to signed-in members, including the 1 later case that cites this judgment.