AWLS and the carriers, Qantas and Los Angeles Airways have been unable to resolve their dispute over moisture damage to a cargo of 'Dr Sage's Special Powders' en route from LA to Melbourne. AWLS argues that the cargo was damaged due to moisture exposure during the flight.

As agreed in an arbitration clause included in their contract of carriage, AWLS and the carriers Qantas and Los Angeles Airways agree to submit their dispute to arbitration proceedings by a sole arbitrator in Australia, under the UNCITRAL Model Law. The airlines and the parties agree to the appointment of Mr Fish, a former lawyer from the US, who recently began working as an arbitrator in Australia.

However, AWLS is unhappy with the way proceedings were conducted. A few days before the arbitration hearings were concluded, AWLS discovered that Mr Fish had worked for Los Angeles Airways as an in-house senior lawyer from 1998 to 2008 and that he continued to hold shares in the business that he accumulated during the ten years of his employment there. Mr Fish did not disclose this information when he agreed to be the arbitrator. When AWLS presented this evidence to Mr Fish during the proceedings and asked Mr Fish to step down, he refused.

Also, on the last day of the hearing, the airlines tabled expert evidence disputing the impact of the cargo-hold temperatures on the powders and Mr Fish refused a request by AWLS for additional time to review this new evidence. Mr Fish's written decision clearly indicates that the new evidence influenced his finding in the airline's favour.

Drawing on relevant rules from UNCITRAL or the IAA as appropriate, and using any cases that support your arguments:

1. QantasandLAAarenowseeking toenforcethearbitrationawardagainstAWLSintheAustralian Courts under the provisions of the Model Law. Discuss how and on what grounds AWLS might challenge the enforcement.
2. How would your response to Q1. be different if the arbitration took place overseas in Singapore and the airlines were now seeking to have the award recognized in the Australian courts?