ISSUE:
Whether the inquiry officer’s bias invalidates the disciplinary proceedings?
Whether the inquiry officer was authorized to conduct the inquiry after his demotion from Director-in-Charge to Deputy Director?
Whether denial of access to relevant documents amounts to a violation of the right to a reasonable defence?
RULE:
A real likelihood of bias exists if reasonable and right-minded individuals, upon considering the facts, would conclude that the inquiring officer was prejudiced.
It is not necessary to prove actual bias; the perception of bias based on objective circumstances suffices to render the inquiry invalid.