In Szilard v. Szasz, 1954 CanLII 4 (SCC), [1955] 1 D.L.R. 370 at pp. 373-4, [1955] S.C.R. 3, Rand J. said: These authorities illustrate the nature and degree of business and personal relationships which raise such a doubt of impartiality as enables a party to an arbitration to challenge the tribunal set-up. It is the probability or the reasoned suspicion of biased appraisal and judgment, unintended though it may be, that defeats the adjudication at its threshold. Each party, acting reasonably, is entitled to a sustained confidence in the independence of mind of those who are to sit in judgment on him and his affairs.
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