Key legal question
Whether the Tribunal d’arrondissement de l’Est vaudois had to be recused in corpore for appearance of bias.
Extracted holding
No. The mere fact that the debtor is the son of a court employee assigned to civil matters did not create serious grounds for bias, especially since she had no decision-making power and worked in a different area from the bankruptcy file.
Extracted reasoning
Recusal is exceptional and requires serious objective grounds. The employee’s role was administrative only, unrelated to the bankruptcy docket, and neither underlying party sought recusal or objected to the procedure.