Lawal v Northern Spirit [2003] UKHL 35

House of Lords

Facts: Lawal challenged the fairness of a decision made by a deputy prison governor. The House of Lords applied the “fair-minded observer” test to determine if there was an appearance of bias.

Held: The House of Lords confirmed that the “fair-minded observer” test should be used to assess the appearance of bias. Even if a decision-maker did not directly participate in the decision-making process, the perception of bias must be addressed.

Judicial Statement: The Court applied the test from Porter v Magill, emphasizing that public perception of bias is crucial, even if the individual concerned did not directly influence the decision.