Recognising these considerations, there are signs of a different reception of Belize in other cases (such as Thomas Crema v Cenkos Securities plc [2011] 1 WLR 2066). Most significantly perhaps, in Stena Line v Merchant Navy Ratings Pension Fund Trustees Ltd [2011] EWCA Civ 543, Arden LJ emphasises the importance of Lord Hoffmann's speech in improving the coherence of the law. At one level, the coherence is found in the subsuming of implied terms under the general cover of interpretation. Thus, at para 36, Lady Justice Arden says:

In Belize, the Privy Council analysed the case law on the implication of terms and decided that the implication of terms is, in essence, an exercise in interpretation. This development promotes the internal coherence of the law by emphasising the role played by the principles of interpretation not only in the context of the interpretation of documents simpliciter but also in the field of the implication of terms. Those principles are the unifying factor. The internal coherence of the law is important because it enables the courts to identify the aims and values that underpin the law and to pursue those values and aims so as to achieve consistency in the structure of the law.