At the start of his paper Keeping Their Heads Above Water? European Law in the House of Lords, Anthony Arnull reports a judgment delivered by Lord Denning in 1979, in the early days of the process of the United Kingdom's European integration. It stated as follows:
[The] flowing tide of the Community law is coming in fast. It has not stopped at high-water mark. It has broken the dykes and the banks. It has submerged the surrounding land. So much that we have to learn to become amphibious if we wish to keep our heads above water.
Lord Denning made a similar remark in his judgment in Bulmer v. Bollinger, which was a pivotal case in the dialogue between the United Kingdom (UK) and European systems.