What is the test for disqualifying an arbitrator?

Manitoba, Canada


The following excerpt is from Simmons v. Manitoba, 1988 CanLII 7440 (MB QB):

Ghirardosi v. Minister of Highways for British Columbia (1966), 55 W.W.R. (N.S.) 750, is authority for the proposition that if there is "... any basis for a reasonable apprehension that an arbitrator might not bring to his judicial task a free, independent and impartial mind, ... his award, or any award in which he played a part, ought to be set aside on the grounds that such arbitrator was, in law, disqualified."

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