Despite the well stated differences between the "real danger" and the "reasonable apprehension" of bias tests as employed by English and Australian courts respectively in determining when a judge should be disqualified by reason of bias, the method of implementation of the latter test over the last decade poses the question whether the differences are more apparent than real. Rather, it is the recent rejection by the High Court of Australia in Ebner v Official Trustee in Bankruptcy of the "automatic disqualification" rule as set out by the House of Lords in R v Bow Street Metropolitan Stipendiary Magistrate; Ex parte Pinochet Ugarte (No 2) which more clearly marks the differences between the jurisdictions in this area of the law.