for a finding of bias. (para. 115) A high standard must be met before a finding of reasonable apprehension of bias can be made. Troubling as Judge Sparks’ remarks may be, the Crown has not satisfied its onus to provide the cogent evidence needed to impugn the impartiality of Judge Sparks. Although her comments, viewed in isolation, were unfortunate and unnecessary, a reasonable, informed person, aware of all the circumstances, would not conclude that they gave rise to a reasonable apprehension of bias. (para. 158) External links Critical Discussion of R. v. R.D.S. at 15 years on LegalEase on CKUT Supreme Court of Canada cases Canadian criminal procedure case law 1997 in Canadian case law