The following excerpt is from Day v. The International Alliance of Theatrical Stage Employees, 2018, 2018 ONSC 6934 (CanLII):
In Tippett v. International Typographical Union (1975), 63 D.L.R. (3d) (B.C.S.C.) Anderson J. addressed the standard to be applied when an allegation of bias is made against a tribunal constituted by a voluntary association such as a union. He held that the member who alleges bias must show a “real likelihood of bias”. In that case, Anderson J. held at p. 540 that there was proof of actual bias on the parts of two members of the tribunal and, at the very least, a “real likelihood of bias”.
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