Question juridique clé
Whether the members of the criminal court had to be recused for apparent bias after the court dispensed a civil party from personal appearance.
Solution extraite
The circumstances did not objectively suggest prejudice; the dispensation was an organizational measure allowed before the hearing and did not mean the judge assumed the civil party was dead.
Motifs extraits
Under the impartiality guarantee, only objectively verifiable circumstances creating an appearance of bias matter. A pre-hearing waiver of personal appearance for a civil party, while leaving open written submissions, is not a sign of preconceived judgment.