in the Federal Court case of Bar Council v Tun Dato’ Seri Arifin Bin Zakaria & Ors [2020] 4 MLJ 773, at [35], Hasan Lah FCJ has applied the “real possibility of bias” test (Real Possibility Test). In Singapore’s Court of Appeal case of Boj v Boj [2018] 2 SLR 1156, at [85] and [93]-[95], Andrew Phang Boon Leong JA has decided as follows - “[85] As we have noted at [69] above, after looking at Gillies ([69] supra), the key point to note is that, after Porter, the test for apparent bias under English law is no longer that propounded by Lord Goff in Gough but is, instead, the same test that obtains in most of the Commonwealth (including Scotland), viz, the “reasonable suspicion of bias” test. Whilst it is true that the House in Porter did not expressly depart from Lord Goff’s approach in Gough, this last-mentioned approach has, with respect, been all but superseded (in substance). … [93] Finally, we note that, on a substantive level, there is no material difference between the “reasonable suspicion of bias” test and the “real likelihood of bias” test. Indeed, it is difficult to see how a reasonable person might reasonably suspect bias without considering that there was a real likelihood of bias (see Auckland Casino Ltd at 149, quoted at [50] above). In this regard, the English decisions of Hannam (in particular, Cross LJ’s remarks at 949, reproduced at [74] above) and Locabail (at [17], see [81] above) also support the view that there is “little (if any) difference” between the two tests and that they would lead to the same outcome in the “overwhelming majority of cases”. We highlight again the observations in Porter, In re Medicaments, Saxmere ([50] supra) and Gillies (see [69] above) that the Porter test (notwithstanding the usage of the phrase “real possibility” in its formulation) aligned the English position with the positions in the Commonwealth and Scotland, ie, the “reasonable suspicion of bias” test. Reference, in this regard, may also be made to the relevant academic literature (see, for example, Lionel Leo and Chen Siyuan, “Reasonable Suspicion or Real Likelihood: A Question of Semantics?” [2008] Sing JLS 446 (“Reasonable Suspicion or Real Likelihood”) at 449 and Tham Lijing, “The Rule Against Apparent Bias – Language Disguising Thought”, Singapore Law Gazette (July 2014) at 21 (“The Rule Against Apparent Bias – Language Disguising Thought”) at 23). [94] However, there is nevertheless both conceptual and practical merit in adopting a standard terminology (see also Reasonable Suspicion or Real Likelihood at p 454). We therefore take this opportunity to state that the appropriate test henceforth is the “reasonable suspicion of bias” test. Indeed, this is (as we have seen) also entirely consistent with the test adopted generally across the Commonwealth. [95] For the reasons set out above, we hold that Re Shankar Alan ([27] supra) and Tang Kin Hwa ([28] supra) do not conflict with each other and (most importantly) that the test that henceforth ought to be applied in respect of the issue of apparent bias is the “reasonable suspicion of bias” test.” (emphasis added). As explained in Boj -