In the quest for routes to resist enforcement of an Adjudicator's decision, parties often turn to the issue of bias of the Adjudicator as a potential ground.
The Court of Appeal decision in In re Medicaments and Related Classes of Goods (No 2) (2001) established the current test for bias. The issue which arose there was whether a lay member of the Restrictive Practices Court was biased. She had applied for a job with a consultancy firm, a director of which was an expert witness in a case she was involved in.