Following on from my overview article on the application for recusal pursuant to Section 42 ZPO, I would like to report on an interesting ruling by the Higher Regional Court of Karlsruhe. According to this ruling, a judge’s failure to read the pleadings submitted by a party can give rise to concerns of bias. In the case in question, a judge had overlooked an application for recusal directed against him, as he had forwarded the pleading containing it unread to the opposing party for comment. This violates the so-called duty to wait pursuant to Section 47 (1) ZPO, according to which only “official acts that cannot be postponed” are permitted from the filing of an application for recusal until it has been dealt with.