CJ never contacted him with regard to housing and that anyone was free to recommend. d. A letter dated January 12th 201820 from the former HDC general manager referring to an alleged policy enabling recommendations from senior public officials for requests for housing for persons in need. e. No documented evidence of follow ups, far less lobbying, after the election, save for disputed WhatsApp messages between the CJ and the PM which will be examined hereunder. f. If the alleged HDC internal email were to be accepted, they reveal that the recommendations were actually being processed. 48. It is in the context of that material that the applicant makes his claim to apprehension of bias including paragraphs 47, 48, and 4921, of his affidavit. See for example paragraph 49 (all emphasis added) The real risk to the fair-minded and informed observer is that, either during the hearing of the petition appeals or shortly beforehand, the Honourable Chief Justice may have been seeking favors from the Government of the day in respect of HDC housing applications. This gives rise to real and substantial concerns of apparent bias and/or apparent unfairness in relation to the Honourable Chief Justice’s participation in decisions affecting the election appeals. I am particularly concerned about the fact that the Honourable Chief Justice wrote the then Managing Director of the HDC on June 26, 20 21 Record of Appeal page 749 pages 47 and 48 of the record of appeal 25

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