The ADR framework has emerged from being classified as an ad hoc means of resolving disputes to become a more traditional form of justice where parties are increasingly opting for ADR as a means of resolve future disputes instead of traditional forms of justice. However, concern over ADR's increasing similarity to traditional forms of justice leaves the question of whether ADR has currently evolved into a new form of traditional contentious justice. It can be argued that the definition of justice varies considerably between the three areas, but a common theme is identifiable. Mediation offers a considerable number of cases the opportunity to pursue dispute resolution in a way that is fair, just and acceptable to the parties, which is not necessarily evident in court procedures. The ability of mediation to enable disputing parties to tailor justice to their particular needs can be seen as an extremely positive development. The increasing use of ADR, including mediation, within the traditional confines of court systems can be seen as a means for courts to manage their workload so that parties do not rely solely on the courts to enforce transactions. But there is one key concern that may require further research. ADR processes could be