There are two well known rules of law which are applied by English courts when one of the parties seeks to rely upon standards found in public international law. Regarding customary international law, Brownlie suggests that this is the rule: 'customary rules are to be considered part of the law of the land and enforced as such with the qualification that they are incorporated only so far as is not inconsistent with Acts of Parliament or prior judicial decision of final authority." However, 'treaties are only part of English law if an enabling Act of Parliament has been passed.'2 Rather than being automatically incorporated like custom, treaty law must be transformed by the legislature if English courts are to be able to apply it.3