In Halliburton Company v Chubb Bermuda Insurance Ltd [2020] UKSC 48, Lord Hodge states , at [1] that [It] is axiomatic that a judge or an arbitrator must be impartial; he or she must not be biased in favour of or against any party in a litigation or reference. A judge or arbitrator, who is not in fact subject to any bias, must also not give the appearance of bias: justice must be seen to be done. This appeal is not concerned with any deliberate wrongdoing or actual bias but with the circumstances in which an arbitrator in an international arbitration may appear to be biased. It raises important questions about the requirement that there be no apparent bias and the obligation of arbitrators in international arbitrations to make disclosure.

This is a Landmark ruling on disclosure by arbitrator. Read the remaining judgment here.

(Right image source: https://www.britannica.com/event/Deepwater-Horizon-oil-spill, accessed 1 Dec 2020)