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The Supreme Court’s judgment in Halliburton Co v Chubb Bermuda Insurance Ltd  UKSC 48;  1 Lloyd’s Rep1 has become the leading English case on arbitrators’ duty of disclosure and test for apparent bias.
The impartiality of arbitrators is a long-debated theme. Under the Arbitration Act 1996 (section 33) arbitrators are under
the duty to act fairly and impartially as between the parties. Absent a legal definition of impartiality, past initiatives
like the IBA Guidelines on Conflicts of Interest in International Arbitration (2004) attempting to create a framework of reference
have not been completely successful in delineating the legal status quo of the impartiality of arbitrators.
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