$100,000-a-day fine back to the Chief Justice would trample "principles against bias''.

He also said the Hon. Sir James Astwood had had no legal powers to impose the "draconian'' fine.

Mr. Hall made the claims as he wrapped up the Bermuda Industrial Union's appeal against the fine and order for its assets to be seized.

Both were imposed after the union allegedly breached a Government-inspired injunction demanding an end to illegal striking during the recent nationwide unrest.

The Chief Justice later made a stay of execution on the order, pending the appeal hearing.

The Court of Appeal will announce its decision tomorrow at 2 p.m., giving reasons later.

Meanwhile, it was claimed yesterday a full Supreme Court trial over the Government-BIU wrangle may be held.

Mr. Philip Holder, from the Attorney General's chambers, said the Chief Justice's rulings so far had been provisional -- and not final.

Government may wish to press for a final judgment over whether the striking was illegal, he added.

"Clearly there is an action here, and on foot, which may continue for a number of reasons.'' Mr. Holder went on to backtrack on an earlier call for the stay on the order to be lifted. He said he now conceded the stay could remain since a full trial was likely.

The appeal hearing has revolved around the BIU's main argument the Chief Justice imposed the penalties at a July 1 hearing of which the union had not even been notified.

Mr. Hall has argued the Chief Justice's ruling amounted to a finding of contempt, and flouted natural justice.

He dismissed Mr. Holder's claims the union should seek redress at the Supreme Court -- before, if necessary, going to appeal.

At the outset yesterday Mr. Holder claimed the BIU was technically still in contempt of court over its alleged injunction violation -- although strikes over the Bermuda Forwarders' dispute had ceased.

"The contempt still exists until the appellants have purged their contempt.'' The BIU had to return to the Supreme Court to purge its contempt, he stressed.

It was, therefore, wrong for the union to be heard now at the Court of Appeal.

Mr. Holder said Government had won the injunction during a June 29 hearing with the Chief Justice.

It had been essential to act quickly in the "public interest'' as the country had been plunged into turmoil.

In matters of urgency, there was no legal requirement for the union to be present, said Mr. Holder.

"If the circumstances warrant the rules of natural justice may be waived.'' Mr. Holder said the injunction was a provisional measure to maintain the "status quo'' until the strike issue had been resolved.

"A final order can only be made after a trial of the action.'' Mr. Hall, in his final submission, repeated claims the Chief Justice had violated rules of the Supreme Court, natural justice, and Bermuda's constitution.