Mr Rokison had previously been appointed on behalf of Chubb in other arbitrations and was currently acting in two arbitrations involving Chubb. He disclosed these facts on appointment. However, he was subsequently appointed in two additional arbitrations involving the Deepwater Horizon fire, one by Chubb against rig owner Transocean and one by Transocean in a claim not involving Chubb but relating to the same insurance layer. He did not disclose these appointments in the Halliburton arbitration. When they came to light, Halliburton sought to have him removed on the basis that the failure to disclose these gave rise to an appearance of bias (that is apparent bias). Rokison apologised but refused to resign. The High Court refused an application for removal in 2017, after which the arbitrations were decided in favour of Chubb. Halliburton appealed to the Court of Appeal and ultimately the United Kingdom Supreme Court. Now, there are situations that most people would agree are patent evidence of actual bias.