The French Cour de Cassation confirmed that the friendship between an arbitrator and the counsel of one of the parties, revealed in a eulogy written by the arbitrator in memory of the counsel, and in which the arbitrator emphasizes his friendly relationship with the deceased, is such as to raise a reasonable doubt as to the independence and impartiality of the arbitrator. Such friendly ties should have been disclosed by the arbitrator in his declaration of independence and impartiality at the outset of the proceedings. The discovery of a friendly relationship that went beyond the realm of academic sociability between the arbitrator and one of the parties' counsels which was not disclosed justifies setting aside the arbitral award for irregularity in the constitution of the arbitral tribunal pursuant to article 1520 2° of the French Code of Civil Procedure (the ‘CCP’).