A big fish in a small pond?

• The Commercial Court has confirmed that repeat appointments in LMAA arbitrations do not automatically imply bias.

The English Commercial Court in V and another; K v V and another [2025] EWHC 1523 (Comm) has confirmed the high threshold required to challenge arbitral awards on grounds of apparent bias and jurisdictional error. The judgment underscores the robustness of the London Maritime Arbitrators Association (LMAA) framework and highlights the importance of context in the approach to arbitrators’ duties of disclosure. The decision also provides further clarity on the application of the principles established in Halliburton Company v Chubb Bermuda Insurance Ltd [2020] UKSC 48.

Background

The seller, K, terminated a memorandum of agreement for the sale of a vessel after US sanctions were imposed on the buyer, V, by the Office of Foreign Assets Control. V had nominated a related party to take delivery