Non-verbal communication between a police officer performing court duties and a juror about matters unrelated to the trial (here, a romantic interest) does not give rise to a reasonable apprehension of bias where the trial judge gives prompt and appropriate directions, the communication has no connection to the merits of the case, and the officer's role is not closely linked to the prosecution. The curative effect of judicial directions is a significant factor in assessing whether such irregularities amount to a miscarriage of justice.
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