Removal of arbitrators: apparent bias

The English courts have accepted that an arbitrator may be removed for demonstrating actual bias or putting themselves in a position where there are circumstances which objectively give rise to the possibility of an appearance of bias. In H v L and Others [2017] EWHC 137 (Comm) the primary allegation – dismissed by the court – was that the arbitrator had wrongly accepted two subsequent appointments creating a risk of overlap but without disclosing those later appointments.

H v L : the facts