This article looks at bias after R v Gough  AC 64 and then again after R v West London Coroner, ex p Dallaglio  in which the Court of Appeal, in down playing the importance of appearances, concluded that Lord Hewart's famous aphorism that “[it is] of fundamental importance that justice should not only be done, but should manifestly and undoubtedly be seen to be done” no longer seemed to be good law. This article looks at the two possibilities this presents, which are (a) Dallaglio misunderstands Gough; or (b) Dallaglio takes Gough to its logical conclusion and it is Gough which is mistaken, and the author suggests that Gough is right and Dallaglio wrong.
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