This is summed up in Bishop and Reed's3 article: ‘An arbitrator who is impartial but not wholly independent may be qualified, while an independent arbitrator who is not impartial must be disqualified. In selecting party-appointed arbitrators in international arbitration, the absolutely inalienable and predominant standard should be impartiality.’ The interchangeable usage of these two terms can be seen in the cases discussed below as well as in the general term of bias used in the Draft Joint Report of the Working Group on Guidelines Regarding the Standard of Bias and Disclosure in International Commercial Arbitration, 7 October 2002 (the IBA Draft hereinafter).