Natural justice – Judge. Following proceedings that alleged two massive frauds, the judge made numerous adverse findings regarding Mr Urumov and found him personally liable in the sum of US$174m. The claimant companies then sought to issue proceedings against Mr Urumov for contempt and committal to prison. On Mr Urumov's application, the same judge recused himself. The Court of Appeal, Civil Division, held that the judge had erred as the established tests for recusal had not been met.