A careless mechanical error occurring before the commencement of driving, which sowed the seed of risk but had been forgotten, is markedly less culpable on the scale of dangerous driving under s 52A(3)(c) than ongoing reckless handling of a vehicle on the road (such as excessive speed, unsafe overtaking, or driving while affected by drugs or alcohol). Failure to register or insure a vehicle are regulatory infringements not bearing upon the objective seriousness of dangerous driving offences where they were not causative of the accident or injury. A sentencing judge's strong criticism of defence representatives for repeated failures to serve material in advance does not give rise to apprehended bias where the criticism is directed at professional and procedural failures rather than the merits of the case.
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