41Mark Gobbi “Dra fting Techniques for  Treaties in New Zea land,  Statute Law Review, Volume 21, Numb er 2, pp 71-103  (2000).      42Hu akina D evelo pm ent Trust v W aikato Va lley Au thority [1987]  NZLR 188.      43Pierson v  Secretary of State [1997] 3 All ER 577, 605. 28 effect to international treaties or conventions to which New Zealand is a party.41 In the same article he notes that in the 1920s and 1930s, no  statutes implemented specified treaties, whereas in the 1980s 13 and in the 1990s 24 statutes implemented specific treaties.  In New Zealand, the Treaty of Waitangi may be relevant depending on the statute involved, irrespective of whether the Treaty is expressly referred to in the statute.42 49 Some statutes embody economic concepts that readers need to be familiar with in order to understand them. Trade practice legislation is a good example. Nor will a reader  of  a  statute  necessarily  know  what  interpretation  has  been  placed  on particular provisions by the courts. In many instances, the written word of a statute cannot safely be relied on without also considering relevant case law. As Lord Steyn has observed ,“[u]ltim ately, common law and statute coalesce in one legal system”.43 A statute that consolidates earlier legislation may just re-enact, with or without modification, earlier provisions that have been given a particular interpretation by the courts. Understanding the thrust of a new statute may necessitate understanding the previous law. It would be impossible to appreciate the effect of reform of a country’s   company  law  without  understanding  the  changes  being  made  to  the previous law. 50 For these reasons, the bare words of a statute tell only a part of the story. Does it matter then how the statute is drafted? As long as the lawyers and judges can make sense of it, does it matter whether anyone else can? Why the obsession with plain language?  The  answers  to  these  questions  are  fairly  obvious.  First,  because