would have permitted the consideration of whether bias was involved in the issuing of two search warrants last October.

The third day of an appeal against two Supreme Court rulings in January and March, which quashed search warrants for the law offices of Hall and Associates issued by Magistrate the Wor. John Judge on October 21 and 22, continued yesterday with more technical arguments about procedure and wrangling over legal precedents.

Hall and Associates lawyer Mr. Robin McMillan, representing lawyer and former MP Mr. Julian Hall, interrupted his submissions yesterday morning in an attempt to raise the question of whether bias may have influenced Mr. Judge when he issued the search warrants.

"One is obviously reluctant to go into that area,'' Mr. McMillan told the three-judge Court of Appeal. He said he was acting on late instructions from Mr. Hall to raise the issue and said he had argued the point during the Supreme Court hearings, but that Chief Justice the Hon. Mr. Austin Ward had not touched on the matter when he ruled in favour of Mr. Hall.

The only prior mention of bias during the current hearing was in an affidavit sworn by Mr. Judge, who acknowledged that Mr. Hall had appeared in his court as a lawyer and said that he had been "informed that he is alleging that I was motivated by some unspecified malice, prejudice or other bias towards him in issuing the above described warrants.'' Mr. Judge denied any bias in his actions toward Mr. Hall.

London lawyer Mr. Michael Tugendhat, QC, representing the Attorney General's Chambers in the appeal, objected to the motion, saying he had no prior warning that it was coming and no time to prepare an argument against it.

"I object as strongly as I can to this, not only for the substance of it but for the manner in which it was raised,'' Mr. Tugendhat said.

"If Mr. Hall really believed there was bias there would have been no natural reluctance at all,'' he said, adding that there was no excuse for raising the matter "at this late stage.'' Appeal Court judges The Hon. Mr. Justice Telford Georges, The Hon Mr. Justice Michael Huggins, and The Hon. Sir James Astwood agreed with Mr. Tugendhat.

"No, we don't think we should allow an amendment at this late stage,'' Mr.

Justice Huggins said after the three briefly conferred among themselves. Other submissions put forward by Mr. McMillan centred around whether Mr. Judge gave due consideration to everything he was required to by law before issuing the warrants and suggestions that Mr. Judge did not properly document his reasons for granting the warrants.

"He should have given a fuller account of the reasoning that led to the issue of the warrants,'' Mr. McMillan said, adding that the burden was on the issuing magistrate to provide satisfactory evidence of the "reasonable grounds to suspect'' -- a requirement of the Drug Trafficking Suppression Act 1988.

He also claimed that if officers conducting the first search warrant were entitled by that warrant to seize the material named in the second warrant then they had "abrogated'' their entitlement by going back for the second warrant.

He also took issue with the wording used to obtain the second warrant, saying that Police Superintendent George Rose told the magistrate that officers needed to gain access to the premises when in fact Police officers were already there because of the first warrant.

The hearing is expected to finish today.