Arbitration – Arbitrator. The claimant owners' appeal against an arbitrator's decision failed. The proceedings concerned an arbitration following the salvaging of a vessel, in which the arbitrator had increased the amount that the defendant salvors were to be awarded. The Commercial Court held that the owners had not been able to establish a breach by the arbitrator of his duty to act fairly, and had not been able to establish the necessary 'substantial injustice', as required by the Arbitration Act 1996.