Alternative dispute resolution has been part of the process of making the work of the courts more efficient and improving access to justice. In WA, developments such as the increase in the number of statutes that provide for mediation, the amendments to the Supreme Court Act 1935 (WA) inserting provisions relating to court annexed mediation, and the recommendation of the Western Australian Law Reform Commission (in the Review of the Criminal and Civil Justice System in Western Australia) that a Mediation Act be enacted, have highlighted the increasing use of mediation to achieve the policy objectives of the civil justice reform and ADR movements.