Whether the request for recusal of the entire Tribunal d'arrondissement de l'Est vaudois should be admitted because one of its members was a party and there was an appearance of bias.
Yes. The court found an objective appearance of partiality because H.________ was both president of the tribunal and a co-owner in the dispute, creating a risk that the parties and third parties would perceive the tribunal as biased.
Under Arts. 47(1)(a) and (f) CPC and Art. 48 CPC, recusal is required for personal interest or other grounds of apparent bias, but only for serious reasons. Here, H.________ could appear both judge and party and her professional ties with the other judges could objectively create an appearance of prevention.