Allegations of actual bias against a judicial officer must be particularised with facts no less fulsome than required for fraud; it is insufficient to refer the reader to expert reports without identifying the specific facts relied upon. Where a party relies on issue estoppel from a foreign judgment, the correctness of that judgment under foreign law is irrelevant to the viability of a collateral attack based on apprehended bias. Institutional or systemic corruption of a foreign judicial system is a justiciable issue, but the facts particularised must be capable of supporting the specific inference sought — general institutional facts without a direct connection to the specific proceeding may be insufficient for actual bias but sufficient for apprehended bias.
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