It is very common, in correspondence or orally, to need to refer to other documents, be they statutes, case-law or evidence. You will very rarely write anything that does not talk about other documents.

It is well worth thinking about how you do this. Writing something like “Such and such was laid out in the company’s policy” can cause problems. Often the policy will be long, and there may even be more than one. Your reader will have to search through pages of documents to find what you are talking about. Even a short submission of a couple of pages, will probably refer to a dozen or so other documents at least, so these problems add up quickly.

It can also cause difficulties for you, since you may well be asked “Where exactly is that?”.

There are basically two ways of avoiding this problem:


Almost every document you will deal with in a case, will have a shorthand way of referring to it.

  • Documents in the bundle can be referred to by page numbers. Some documents also have paragraph numbers you can use.
  • Cases can be referred to by their case citation. You can use page numbers, paragraph numbers and marginal letters to give more precise references.
  • Witness statements can be referred to by paragraph numbers.
  • Statutes are referred to using the name of the statute and section numbers.

Using these references is simple. For example,

Mr White, at paragraph 6 of his statement, says that the bonus scheme was organised on a commission basis, bundle p78, para. 5.

Many people like to put references in italics. This can be useful.

Another useful technique, particularly when you will be referring often to the same source, is to indicate a default reference. For example, you might write at the beginning of a submission “Page references are to the bundle of documents, unless otherwise indicated”. This allows you to avoid writing ‘bundle’ repeatedly.


Sometimes, it will be useful to quote from documents, rather than just providing a reference. There is no absolute rule as to when a quote is better that a reference. It is mostly a matter of common sense. Your aim should be to make things easy for the reader. If a quote will help them, put one in.

In general, the more important a document and the more you want to say about it the more likely that a quote is sensible.

Bear in mind that quotations break up what you are writing. Too many quotes will make it difficult to follow what you are saying, since you will keep stopping to insert a quote. The aim is to achieve a happy medium between giving your reader useful information and making your points concisely.

A quotation should always have a reference attached, so that the reader can follow up the quote and see it in its original context.

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