The decision confirms that the test for actual bias requires showing the decision-maker was so committed to a conclusion already formed as to be incapable of alteration, and that a tribunal member's procedural management of a self-represented litigant (including directing cross-examination, questioning relevance, and correcting procedure) does not establish actual or apprehended bias. Cancellation of registration and indefinite disqualification is an appropriate sanction where a medical practitioner demonstrates extensive professional misconduct across multiple allegations, a prior disciplinary history including deregistration, and little insight into deficiencies.
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