A magistrate is under investigation after refusing to deal with a defendant wearing a full Muslim veil.
Ian Murray refused to deal with the case
Ian Murray walked out of a case at Manchester Magistrates' Court last week because Zoobia Hussain, 32, of Crumpsall, was covered by a niqab.
A formal letter of complaint from Ms Hussain's lawyer was received by the court triggering the inquiry.
An internal investigation is being carried out, the Judiciary of England and Wales said.
Ms Hussain appeared at court on Thursday before three magistrates on a charge of criminal damage.
Mr Murray walked out, claiming her full face veil raised issues of identity.
Zoobia Hussain's case was adjourned
The Magistrates' Advisory Committee in Manchester is working with the magistrate to investigate the incident, a Judiciary spokesman said.
"Once that is done, a decision will be taken as to whether a full investigation will take place.
"Such an investigation would be conducted by an appeal panel of local magistrates."
Ms Hussain's lawyer, Judith Hawkins, said the young mother was "shocked and distressed" and found Mr Murray's treatment of her "insensitive and unacceptable".
Before he walked out, Ms Hawkins told the bench her client was a practising Muslim who covered herself in public places where men were present as part of her religion.
Last week, a judiciary spokesman said Mr Murray agreed he "acted unwisely" by walking out without giving reasons and "regrets" that his behaviour could be interpreted as intolerant of other cultures.
The judiciary's guidelines state situations should be judged on a case-by-case basis.
But they say there should be a "willingness to accommodate different practices and approaches to religious and cultural observance", provided "justice can be properly served".
Ms Hussain's case was dealt with after Mr Murray withdrew and was adjourned until 18 July.