Competition Commission v BAA Ltd & Anor

Competition Commission v BAA Ltd & Anor

Apparent bias did not exist before 2 December 2008 as Professor Moizer's relationship was solely with the Fund and not with MAG or the local authorities; after 2 December 2008, apparent bias existed but did not contaminate the Panel's final decision, and BAA did not waive its right to object.

Parties
Appellant: Competition Commission; Respondent: BAA Limited; Intervener: Ryanair Ltd
Jurisdiction
England and Wales
Judgment Date
13 October 2010
Procedural Posture
Appeal / Judgment
Outcome
Appeal allowed; Competition Commission's decision restored.
Legal Topics
Apparent Bias, Waiver, Contamination of Tribunal, Enterprise Act 2002, Market Investigation, Divestiture

Case Brief

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Parties

Competition Commission

Appellant

BAA Limited

Respondent

Ryanair Ltd

Intervener

Procedural Posture

Appeal / Judgment

  1. 1 Whether Professor Moizer's connection to the Greater Manchester Pension Fund constituted apparent bias in the Competition Commission's market investigation.
  2. 2 Whether BAA waived its right to object to apparent bias.
  3. 3 Whether apparent bias contaminated the Panel's decision.

Ratio Decidendi

Apparent bias did not exist before 2 December 2008 as Professor Moizer's relationship was solely with the Fund and not with MAG or the local authorities; after 2 December 2008, apparent bias existed but did not contaminate the Panel's final decision, and BAA did not waive its right to object.

Court Disposition

Appeal allowed; Competition Commission's decision restored.

Orders

  • The appeals are allowed.
  • The decision of the Competition Commission is restored.