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The fair-minded and informed observer would conclude that there was no real possibility of apparent or unconscious bias where, shortly before completing and issuing an award, the arbitrator had disclosed that he had been instructed by the defendant's solicitors in an ongoing matter which was wholly unconnected with the arbitration. The fact that disclosure was late was not a serious irregularity within the meaning of the Arbitration Act 1996 s.68.

Judgment: 
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