Mutual Shipping Corpn. of New York v. Bayshore Shipping Co. of Monrovia (The Montan) - Court of Appeal (Sir John Donaldson M.R., Robert Goff L.J. and Sir Roger Ormrod) - 21 December 1984

Accidental error in arbitrator’s reasons not forming part of award - Whether arbitrator can correct under “slip rule” - Whether Court can remit award

Disputes were referred to arbitration which involved the correct balance of account between charterers and owners following the completion of a time-charter. There were a number of individual disputes on specific items, one of which involved the extent to which the vessel had consumed less fuel than the warranted consumption. The arbitrator was not asked to make a reasoned award. After the hearing he published a short award holding that the owners had succeeded in their claim to the extent of $62,402. In accordance with the usual practice, the arbitrator also provided the parties with copies of confidential reasons which were expressly stated not to form part of or to be used in any way in connection with the award. The reasons formed no part of the award.