203 ARBITRATION LAW a significant uncertainty for arbitrators, especially when institutional rules defer from custom and practice. Some also criticize the ruling because it lacks the necessary clarity on the statutory description of what an arbitrator is expected to be under the Arbitration Act. Lastly, negative comments have been made concerning the outcome of the case, criticising the fact that the Supreme Court found a violation without assessing any consequences. Despite all of the heat it received, the Halliburton decision will remain a landmark decision on the duty of disclosure and apparent bias in English law. It is of significant importance because it is the first time the UK Supreme Court recognized the level of the duty of disclosure, while making it clear that this duty does not supersede the duty of confidentiality under English law.
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