Applicants’ Reply on Annulment

Opening of the document

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES GABRIEL RESOURCES LTD. AND G ABRIEL RESOURCES (JERSEY) L TD. ICSID CASE NO. ARB/15/31 APPLICANTS’ REPLY ON ANNULMENT Counsel for Applicants APPLICANTS’ REPLY ON ANNULMENT TABLE OF CONTENTS THE ENTIRE AWARD MUST BE ANNULLED ON THE GROUNDS OF ICSID A. The Tribunal Was Not Properly Constituted Because a Reasonable and Informed Third Party Could Justifiably Doubt Prof. Douglas’ Impartiality All Arbitrators Must Be – and Must Appear to Be – Impartial and The Standard Is Objective and Does Not Require Proof of Actual Bias or Respondent’s Argument That the Standard Is “Extremely High” Is An Arbitrator’s Disclosure Obligation Encompasses …