The discovery by the English courts in 1975 that they possessed power to restrain a defendant from removing his assets from the jurisdiction, and thereby rendering himself “judgment-proof”, was not only an important—indeed, crucial—development in the English civil law procedure: it also demonstrated the innate superiority of judge-made law over statutory reform. Judge-made law is flexible, develops easily and adapts to changing circumstances. Statutory amendment of the law is its own worst enemy: unlike case law, it is clear that there is a limit, and statutes are construed minutely and exactly according to the words. By contrast, we are constantly taught that judicial decisions are not to be construed as if they were statutes. Indeed, as Lord Denning would say, take this very case. If, immediately after the two decisions founding this jurisdiction (Nippon Yusen Kaisha v. Karageorgis [1975] 1 W.L.R. 1093 and the Mareva case itself [1975] 2 Lloyd’s Rep. 509), it had been decided to encapsulate this significant reform in statutory form, no one can be in any doubt that it would have been extremely hard to urge the courts thereafter to extend the Mareva injunction, first to cases of dissipation of assets within the jurisdiction, then to foreign defendants resident within the jurisdiction, and then to English resident defendants. Yet all of this happened through judicial decision. Furthermore, on the one occasion when statute did purport to make a reform, namely s. 37(3) of the Supreme Court Act 1981 (which was intended to make clear that the Mareva jurisdiction extended to English residents), it was rendered obsolete by case law before it ever came into force.