Reasonable apprehension of bias requires objective proof; vague suspicion is not enough to revoke an arbitrator's authority.

An arbitrator's authority cannot be revoked on vague suspicion or a party's subjective loss of confidence; the governing test is whether a reasonable and fair-minded person would find a real likelihood of bias. The alleged grounds did not meet that standard: failure to record extended arguments or give a speaking order on preliminary objections at an interlocutory stage, refusal to state a special case under the Arbitration Act, 1940, differences in hearing time between references, venue change for practical reasons, and complaints about expenses did not show prejudice. Viewed against repeated attempts to delay the proceedings, the challenge was correctly rejected and no reasonable apprehension of bias was established.

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Issues: Whether the authority of the sole arbitrator was liable to be revoked on the ground of a reasonable apprehension of bias.

Analysis: Revocation of an arbitrator's authority requires more than vague suspicion or a party's subjective loss of confidence. The proper test is whether there exists a real likelihood of bias judged from the standpoint of a reasonable and fair-minded person. The circumstances relied upon did not establish bias: the arbitrator was not bound to record extended minutes of arguments or pass a speaking order on preliminary objections at an interlocutory stage; refusal to state a special case under section 13(b) of the Arbitration Act, 1940 did not create bias; the difference in the time taken for hearing separate references, the change of venue for practical reasons, and the allegations concerning expenses did not show prejudice. The conduct complained of was also viewed in the context of repeated attempts to delay the proceedings.

Conclusion: The application for revocation of the arbitrator's authority was rightly rejected, as no reasonable apprehension of bias was made out.

Ratio Decidendi: An arbitrator cannot be removed merely on vague or subjective suspicion; revocation is justified only where there is a real and reasonable likelihood of bias established from an objective standpoint.

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