“The sheer volume of international arbitration in England, and particularly in London, is such that the daily experience gained by lawyers, arbitrators, and judges in the practical application of the law to the changing needs of commercial arbitration has kept the law, as enacted and as developed through the cases, both rich in depth and well abreast of contemporary demands. The system is, moreover, familiar to, and accepted and trusted by a very large international community… The argument in favour of enacting the Model Law in the interests of harmonisation, or of thereby keeping in step with other nations, are of little weight. The majority of trading nations, and more notably those to which international arbitrations have tended to gravitate, have not chosen thus to keep in step. There would in our judgment be undoubted disadvantages in introducing a new and untried regime for international commercial arbitration, with all the transitional difficulties that this would entail, and at the same time retaining the present regime for domestic arbitration.”