Question juridique clé
Whether a judge must be recused because the party filed a criminal complaint against him and alleges bias.
Solution extraite
A criminal complaint by a party is, by itself, only an indication of the complainant's animosity and does not objectively justify suspicion of bias by the judge.
Motifs extraits
Judicial recusal is exceptional and requires serious objective grounds. A litigant cannot, by merely filing a complaint against a magistrate, prevent him from exercising his judicial function. Only a grave and serious accusation might exceptionally justify doubts about impartiality, which was not the case here.