Africa Sourcing Cameroun LTD & Anor v. LMBS Societe Par Actions Simplifiee & Anor. [2023] EWHC 150 – 27 January 2023 (Sir Ross Cranston)

The Claimant cocoa traders sought to set aside an Award of the Board of Appeal of the Federation of Cocoa Commerce (FCC), on the basis of 'serious irregularity' (s.68)  alleging bias of the Tribunal's chairman due to reasons including his participation in and querying of the Claimants' earlier application for FCC membership, his socialising with and previous trading with Defendants.  The Court found no breach of any disclosure duty by the chairman and that a fair minded and informed observer would not consider that his limited involvement with the Defendants gave rise to a risk of bias. The Award (ruling that the Claimants' claim was time-barred) was confirmed.