The apprehended bias principle has limited application to rate-fixing decisions of local councils, which are quasi-legislative in nature; a councillor's interest as a ratepayer in the local government area is too remote to found an apprehension of bias, particularly where the statutory scheme (ss 442(2) and 448(b) of the Local Government Act 1993) expressly permits participation without disclosure. A challenge to the creation of a rating sub-category on grounds of manifest unreasonableness will be difficult to sustain where the statute confers broad discretion without specific criteria constraining the exercise of the power. Failure to comply with the notice requirement in s 520(1) of the Local Government Act 1993 does not invalidate a declaration of a sub-category.
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