The most important questions on the agenda is what is the New Zealand Law Commission going to recommend and what is the New Zealand Parliament going to implement in relation to the adoption of the Model Law for international arbitrations and perhaps also its adoption in a modified form for domestic arbitration too. It is clear from the discussion paper published by the Commission in 1988 (Preliminary Paper No 7 Arbitration) that its thinking at that date favoured the adoption of the Model Law. Having regard to the recent legislation in Australia and the desirability of some uniformity of approach in the same part of the world it is easy to see why the Commission began by taking that view. Since the publication of the Preliminary Paper time has moved on. Many submissions have no doubt been received by the Commission and it has reached its conclusions. I have not seen the recommendations in their final form, but without disclosing any confidence, it seems a reasonable guess to make that the Commission will come out in favour of the adoption of the Model Law for international commercial law arbitrations and of its adoption in a modified form for domestic arbitrations. This means that the Commission will have concluded that the recommendations to the contrary which have been made by a powerful committee in England are not persuasive in the New Zealand context. In the United Kindgom we have (what seems at first sight) the remarkable spectacle of one set of recommendations for England and Wales and a completely contrary set for Scotland. I refer on the one hand to the Report of the Departmental Advisory Committee on Arbitration Law (Chairman Lord Justice Mustill) published in June 19891 and to the Report of the Scottish Advisory Committee on Arbitration Law …