The prevailing view that a trial judge's refusal to recuse for bias is not an 'interlocutory judgment or order' amenable to appeal under s 5F(3) of the Criminal Appeal Act 1912 (NSW) was confirmed, though the question was not definitively resolved. Adverse rulings, even considered cumulatively, do not without more establish apprehended or actual bias. An applicant who voluntarily terminates legal representation and then seeks a lengthy adjournment faces a heavy burden in demonstrating House v The King error.
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