The applicant lawyer sought judicial review to stop the Law Society from proceeding with a disciplinary hearing against him.
He argued that because the Law Society's Compensation Fund had already paid a claim to a former client based on a finding of his 'dishonesty', the disciplinary panel would be institutionally biased.
The Divisional Court dismissed the application, holding that the Law Society Act explicitly authorizes the overlapping functions of compensation and discipline.
Following established jurisprudence, the court found that the exercise of these dual statutory functions does not give rise to a reasonable apprehension of bias unless the administrative body overextends its authority, which did not occur here.
