agreement from the chosen arbitrators the High Court appointed M. M had disclosed, before the selection process, that he had previously acted as arbitrator in numerous arbitrations in which Chubb had participated. Subsequently, Chubb appointed M as an arbitrator in an excess liability claim arising out of the oil spill made by Transocean under its liability insurance policy with Chubb (Reference 2). Prior to this appointment, M disclosed to Transocean his appointment in the Halliburton arbitration and other Chubb arbitrations. Transocean raised no objection. M, however, did not disclose this to Halliburton. M also subsequently accepted an appointment as a substitute arbitrator in another claim made by Transocean against a different insurer on the same layer of insurance (Reference 3). This was also not disclosed to Halliburton. All is revealed to Halliburton When Halliburton realised that M had not disclosed these two appointments to them, they wrote to M, referring to the International Bar Association Guidelines on Conflicts of Interest in International Arbitration. They argued that he had a continuing duty of disclosure regarding potential conflicts of interest, and asked for clarifications and explanations. M responded with an explanation of how he had come to be appointed and admitted that it did not occur to him at the time that he was under any obligation to disclose these appointments to Halliburton. He explained that while he still did not think the circumstances put any obligation on him to make a disclosure to Halliburton, he appreciated that with "the benefit of hindsight, that it would have been prudent for me to have informed your clients…and I apologise for not having done so." In a later letter to the parties M made it clear that he had no wish to continue to serve as chairman of a tribunal in a case where one of the parties had expressed serious doubts about his impartiality. However he felt that he could not resign without the consent of Chubb, which Chubb was not prepared to give. He asked the parties to put aside their differences and agree a mutually acceptable replacement chairman. However no such agreement was reached and shortly after Halliburton issued a claim form seeking an order pursuant to section 24(1) of the Arbitration Act 1996 (the 1996 Act) to remove M as an arbitrator [1]. High Court Decision Halliburton's application to remove M was heard at first instance by Mr Justice Popplewell: • Popplewell J rejected Halliburton's suggestion that M's appointment in References 2 and 3 involved him being given a secret benefit by Chubb in the form of remuneration he would earn from the arbitrations. He also rejected Halliburton's contention that the overlap of references was a matter of concern and commented