Justice must “not only be done, but should manifestly and undoubtedly be seen to be done” . The recent English case of Sierra Fishing Company & Ors v Farran & Ors [2015] EWHC 140 (Comm) illustrates the judicial reasoning applicable to applications to remove an arbitrator under s. 24 of the Arbitration Act 1996 (the “Act”) on the basis of justifiable doubts in respect of impartiality.