A decision refusing a sequestration order in bankruptcy proceedings does not create an issue estoppel as to the existence of a debt, because the judge in bankruptcy is not required to determine rights inter partes but only whether the discretion to make the order should be exercised. Similarly, a decision dismissing a winding up application where the debt is found to be genuinely disputed does not finally determine the question of indebtedness. Findings by police in an investigation report cannot found an issue estoppel as they are not decisions of a judicial tribunal. A trial judge's management of self-represented litigants, including interruptions to prevent irrelevant evidence and refusal to consider matters that do not give rise to an issue estoppel, does not give rise to apprehended or actual bias.
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