Article from: TDM 2 (2006), in Procedure, Advocacy, Strategy and Tactics in Arbitration
On 19 October 2005, in a decision that has already attracted some criticism, The Hon. Mr. Justice Morison, sitting in the English Commercial Court, decided that the third member of an arbitral tribunal (an English QC) should resign due to the appearance of bias. He did so despite the fact that a specific application appears not to have been made under s.24 of the Arbitration Act 1996. The case marks an inauspicious debut in the English courts of the IBA Guidelines on Conflicts of Interest in International Arbitration.
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S. Friel; "Removal of an English arbitrator for reason of "apparent bias". A.S.M. Shipping Ltd. of India v. T.T.M.I. Ltd. of England"
TDM 2 (2006), www.transnational-dispute-management.com