Paul Davies. JC Smith's The Law of Contract (2018 2 ed). p. 441.
In Blake, Lord Nicholls made it clear that the gain-based remedy will be granted only in ‘exceptional circumstances’. Te usual remedies for breach of contract should be ‘inadequate’, and the claimant should have a legitimate interest in preventing the defendant’s proft-making activity and depriving him of his proft. Lord Steyn said that ‘[e]xceptions to the general principle that there is no remedy for disgorgement of profts against a contract breaker are best hammered out on the anvil of concrete cases’.8 That anvil has rarely been struck. Indeed, it now looks like the decision of the House of Lords in Blake is something of an outlier.
8 Blake, 291.
Although I don't understand this symbolism with anvils, I can surmise the meaning: Steyn is saying that exception to this general principle ought be developed in cases in the future dealing with this legal issue. Then Davies is saying that there haven't been such cases.
But I still yearn to understand the metaphor to anvils.
Although they’re often seen in cartoons and TV programmes and mentioned in almost everything else involving judges, the one place you won’t see a gavel is an English or Welsh courtroom – they are not used there and have never been used in the criminal courts.
Why symbolize "judge-made law developed on a case-by-case basis" by hammering on an avail?
What's the figurative meaning of "That anvil has rarely been struck"? What does not striking an anvil symbolize?