Snell and Snell (No. 2)

In *Snell and Snell (No. 2)*, the Father applied for Justice Kent to recuse himself from hearing the trial of the proceedings on the grounds of bias. The Mother was the respondent.

The central legal issue before the Court was whether there was a sufficient apprehension of bias on the part of Justice Kent to warrant his recusal from the proceedings.

Justice Kent dismissed the Father's application, finding that there was no reasonable apprehension of bias. His Honour applied the established legal test for apprehended bias, which requires consideration of whether a fair-minded lay observer, having considered the facts, would have perceived that the judge was not impartial. His Honour concluded that the circumstances did not give rise to such an apprehension.

The Father's oral application for recusal was dismissed.