A tribunal member who seeks a personal favour (such as a reference) from a party to a current proceeding creates a reasonable apprehension of bias that is not excused by the inherent features of the fixed-term appointment system. The bias arises regardless of whether the favour is granted or refused, because the observer might apprehend influence either from gratitude or from disappointment. The decision also confirms that the 'built in' acceptance of features inherent in a tribunal system does not extend to voluntary conduct by the member that creates a personal obligation to or grievance against a party.
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