To set aside a settlement agreement on grounds of duress allegedly caused by a judicial officer's conduct at a directions hearing, the applicant must establish by cogent evidence that the judicial officer engaged in illegitimate conduct, that this caused the applicant to enter the settlement, and — because the judicial officer is not a party to the settlement — that the other contracting party had actual or constructive notice of the duress. A rational, contemporaneous explanation for the settlement that is inconsistent with duress will be fatal to such a claim.
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