> The ideal system of arbitration law in the view of the Committee is one which gives the parties and their arbitrators a legal underpinning for the conduct of disputes which combines the maximum flexibility and freedom of choice in matters of procedure with a sufficiently clear and comprehensive set of remedies which will permit the coercive, supportive and corrective powers of the courts to be invoked when, but only when, the purely consensual relationship have broken down. Report of the Mustill Committee , par 75 Arbitration International 3 (1990). In June 1989 a committee, chaired by Lord Justice Mustill, recommended against adoption in England. In September 1989 the Scottish Office announced that Scotland would adopt the Model Law for international commercial arbitration. In Australia, following a report from a Working Party, in 1989, the Model Law, with some additions, became Part III of the International Arbitration Act 1974 (C'th). The provinces in Canada as well as Federal Parliament have adopted the Model Law. The Law Reform Commission of Hong Kong has recommended that the Model Law be adopted. Nigeria and Cyprus have already adopted the Model Law. Why, of the Commonwealth countries, did only one, England, decide against adoption? The Mustill Committee considered that the first three, out of the four categories into which it divided the countries of the world, could with advantage adopt the Model Law. The categories were: 1. States with no developed law and practice in the field of arbitration. 2. States with a reasonably up-to-date body of arbitration law, which has not been greatly used in practice. 3. States with an outdated or inaccessible body of arbitration law. 4. States with an up to date body of arbitration law and with a sufficient volume of arbitrations over a sufficient period to have permitted the growth of an expertise in …