Question juridique clé
Whether the investigating magistrate had to be recused because she issued several penal orders that were later not accepted.
Solution extraite
No recusal was required; repeated penal orders and continued investigation did not objectively show bias.
Motifs extraits
For an investigating officer, provisional assessments and even repeated unsuccessful penal orders do not by themselves create an appearance of partiality. Only particularly grave or unusually frequent errors amounting to a serious breach of duty could justify recusal, and such circumstances were not shown.