Shadow Secretary of State for Digital, Culture, Media and Sport Estate. Should the relevant party take office, the Shadow Secretary would be a likely candidate to become Culture Secretary. The post became necessary when John Major created the Department of National Heritage in 1992. When the Coalition Government took office, they merged the office of Culture Secretary with that of Minister for the Olympics (Jeremy Hunt had shadowed both roles in Opposition). Labour retained as its Olympics spokesperson Tessa Jowell, who had been Olympics Minister from the inception of the office. Because it never merged the responsibilities, it has retained the name "Culture, Olympics and Sport" (as has indeed the
Doctrine of bias in Singapore law of an adjudicator will not be permitted to destroy the only tribunal with power to act. The rule applies regardless of whether the disqualification arguably arises from the combination of prosecutorial and judicial functions, pecuniary interest, personal hostility or bias. However, there are limitations to the rule of necessity. One suggested limitation is that the rule is inapplicable if the disqualification of a member will still leave a quorum of an administrative agency capable of acting. Another is that the rule of necessity will not justify an adjudicator sitting where actual bias can be shown. Upon disclosure that the judge