In Halliburton Company v Chubb Bermuda Insurance Ltd,(1) the Supreme Court unanimously upheld the Court of Appeal's decision to dismiss an application to remove an arbitrator on the grounds of apparent bias. The Supreme Court confirmed the Court of Appeal's decision that arbitrators are under a duty to disclose appointments in references concerning the same or overlapping subject matter with a common party, although the Supreme Court's reasoning differed. On the facts of this case, while the Supreme Court found that the arbitrator had breached his disclosure obligations, it further held that an objective observer would not have justifiable doubts as to the arbitrator's impartiality.