Arbitral award challenge fails where bias or natural justice breach is unsupported by cogent material and fair hearing was given.

An arbitral award will not be set aside for bias, misconduct, or breach of natural justice unless the challenger produces cogent material showing predisposition, malice, or denial of a fair hearing. Here, the arbitrator had called for the record, sought the parties' papers, fixed final hearing dates, and proceeded after giving both sides an opportunity to present their case. The complaint that the proceedings moved quickly or that further adjournment was refused did not by itself establish unfairness, particularly where the record showed repeated delay by the appellant. The challenge to the award therefore failed and the award was upheld.

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Issues: Whether the arbitral award was liable to be set aside for violation of natural justice, bias, misconduct, or undue haste in the conduct of the proceedings.

Analysis: The dispute had remained pending for many years and the arbitrator had received the earlier record, sought the parties' papers, fixed final hearing dates, and proceeded after granting opportunity to both sides. The challenge to bias was unsupported by cogent material, and the record showed that the appellant had repeatedly delayed the proceedings. Mere allegations that the arbitrator acted quickly or declined further adjournment did not establish bias, especially when opportunity to present the case had been afforded and the award was made within the time available. In the absence of proof of malice, predisposition, or denial of a fair hearing, no misconduct or breach of natural justice was made out.

Conclusion: The award was not vitiated by bias, misconduct, or violation of natural justice, and the challenge to the award failed.

Final Conclusion: The award was upheld and the challenge proceedings were rejected, leaving the respondent successful.

Ratio Decidendi: A challenge to an arbitral award on the ground of bias or procedural unfairness must be supported by cogent material showing a reasonable apprehension of predisposition or denial of fair opportunity; mere assertions of haste or dissatisfaction with the conduct of the proceedings are insufficient.

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