Question juridique clé
Whether the recusal request was filed without delay under Art. 58(1) CPP.
Solution extraite
The applicant knew the decisive facts by mid-December 2012 at the latest, yet waited until 14 March 2013; the request was therefore untimely.
Motifs extraits
A recusal motion must be made immediately once the ground is known. Parallel criminal proceedings do not justify delaying recusal until a complaint is filed, and no force majeure was shown.