The bias rule requires that decision-makers approach their tasks in an impartial manner. As with the hearing rule, the bias rule can be stated as a single abstract principle but its application will vary according to the circumstances in which it is applied. This article examines the application of the bias rule to royal commissions, with particular reference to a bias application that was made to a royal commissioner and former Justice of the High Court of Australia. The article argues that the commissioner in question got the law right but its application wrong.