An electrode array has an elongate flexible carrier that, when viewed in cross-section, is much more flexible in a first direction than in a second direction orthogonal thereto. The elongate flexible carrier is formed with a bias force that causes the array to flex in the first direction so as to assume the general spiral or circular shape of the scala tympani duct within the cochlea. The less-flexible direction is the direction that makes it difficult for the array to twist as it is inserted within the scala tympani duct. The bias force is sufficiently strong to cause the array to assume its preformed spiral shape even after being straightened during initial insertion into the cochlea. Electrode contacts, embedded into the carrier so as to be exposed along an inner or concave surface of the spiral, thus wrap snugly around the modiolus, thereby positioning the electrode contacts against the modiolar wall in an optimum position for stimulation.