The case provides a comprehensive illustration of the application of apprehended and actual bias principles in the context of a self-represented accused in a sexual offence trial. It confirms that a trial judge's necessary interventions to manage a self-represented accused's irrelevant or prejudicial submissions do not constitute bias, and that a judge's conduct must be evaluated in light of any provocation offered by the accused. It also confirms that complaints about former legal representatives who did not represent the accused at the relevant trial do not establish miscarriage of justice without evidence of actual prejudice to the trial.
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