MANAK LAL vs DR. PREM CHAND

The Supreme Court held that the tribunal constituted under the Bar Councils Act was improperly constituted due to the appointment of a member with a potential bias, violating the principle that tribunal members must act impartially. The Court emphasized that the test for bias is whether a litigant could reasonably apprehend bias affecting the tribunal's decision. The Court also ruled that the objection to the tribunal's constitution could be waived if the party was aware of the facts and their right to object, which was applicable in this case. The High Court's order removing the advocate's name from the rolls was upheld as justified due to serious professional misconduct.