Where ex parte communications between one party's solicitor and a judge's associate occur but are subsequently disclosed before any decision is made, and the judge affords full opportunity for argument on any issues arising from the communications, the disclosure and corrective measures can dispel any reasonable apprehension of bias. The case also confirms that a prisoner's impecuniosity and the control exercised by prison authorities over the prisoner's finances do not, without more, warrant departure from the usual principle that costs follow the event.
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