Key legal question
Whether the investigating judge had to be recused for bias after handling a prior case against the appellant and then his counter-complaint.
Extracted holding
No recusal was warranted. The same judge may investigate reciprocal criminal complaints between the same parties when the facts are linked, absent unlawful methods or signs of partiality.
Extracted reasoning
An investigating judge need not remain completely neutral like a trial judge, but must investigate for and against the parties. Here the counter-complaint concerned the same factual complex and similar allegations, yet the parties' roles were reversed. The prior referral for trial and the earlier consideration of a conviction order did not show inability to act impartially.