What is the test for reasonable apprehension of bias in the context of an administrative board?

In McCormack v. Toronto Police Service, [2005] O.J. No. 5149, at para. 20, Then J. held that the same reasonable apprehension of bias test applies to administrative boards and, in particular, those which are adjudicative in nature, “to provide procedural fairness, an essential ingredient of which is that the board be free of a reasonable apprehension of bias.”

This test is equally applicable to an arbitrator who acts in a judicial or quasi-judicial capacity: Szilard v. Szasz, 1954 CanLII 4 (SCC), [1955] S.C.R. 3, at p.4.

Actual bias does not have to be established. It is the existence of a reasonable apprehension of bias and not the existence of actual partiality by which bias is judged: Ghirardosi v. Minister of Highways for British Columbia, 1966 CanLII 47 (SCC), [1966] S.C.R. 367.