This was a case involving a juror who was the next door neighbour of the brother of the accused but swore an affidavit that she wasn’t aware of the fact until after the jury delivered its verdict. The court refused to quash the decision on the basis of bias, since the test for bias is whether there was a “real danger” that a trial may not have been fair as a result of bias- the “real likelihood” test. This is in contrast to Lord Denning’s “reasonable suspicion” test.
Lord Goff: There is only one established special category where the law assumes bias and that exists where the tribunal has a pecuniary or proprietary interest in the subject matter of the proceedings. The courts should hesitate long before creating any other special category.