Where a jury foreperson's note indicates that jurors have prejudged the case from the outset of the trial, a reasonable apprehension of bias arises that cannot be cured by judicial directions, particularly where the prejudgment preceded the hearing of evidence. The trial judge must apply the objective reasonable apprehension test from Webb v R, not the actual bias test, when deciding whether to discharge the jury. A retrospective direction given after the evidence has concluded cannot undo prejudgment that occurred before the evidence was heard.
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