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Bihar State Mineral Dev. Corpn. & Anr vs Encon Builders (I) Pvt. Ltd on 21 August, 2003

Corpn. Vs. Encon Builders (I) Pvt. Ltd. reported in (2003) 7 SCC 418] was pressed into service, wherein Hon'ble Supreme Court had quoted with approval from the 22nd Edition of 'Russell on Arbitration'. A perusal of Encon Builders brings to light that besides drawing distinction between actual bias and apparent bias (actual bias is rarely established), Russell's view that pecuniary interest in one of the parties or otherwise being so closely connected with one of the parties is a disqualification qua an arbitrator has been referred to. While in the normal circumstances, there would not have been much difficulty for a petitioner to successfully advance such an argument, in the instant case, there are seven striking aspects of the matter, which prevent this principle of bias (that too perceived bias without any shred of material regarding fraud or corruption) from coming to the aid of the petitioner and they are as follows :
Supreme Court of India Cites 12 - Cited by 137 - S B Sinha - Full Document
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