The case confirms that where a juror is discharged for apprehended bias during trial, the question whether the trial judge was required to make further enquiries of the remaining jurors to ensure they were not 'infected' by the discharged juror's bias is a matter that may be raised on appeal, but the prospect of success on such a ground must amount to a strongly arguable case to support bail pending appeal. The court left open the substantive question of whether such further enquiry is required.
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