In a jury trial, the test for apprehension of bias is whether a reasonable juror might have apprehended that the judge might have formed a fixed opinion as to the guilt of the accused, not the ordinary fair-minded lay observer test. A trial judge's duty to a self-represented accused extends to explaining relevant legal matters but not to advising on the basis of objections to particular evidence. There is no rule of law or practice preventing the prosecution from making a closing address when the accused is unrepresented; the judge need only intervene if the address risks a miscarriage of justice. Discounts for guilty pleas under s 53A(2)(b) of the Crimes (Sentencing Procedure) Act 1999 (NSW) are to be reflected in indicative sentences, not applied to the aggregate sentence.
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