It is often useful to number issues or similar topics. It provides structure and organisation. For example, in a written submission it is common to see something like:
- Was Mr Smith an employee of Widget Makers Incorporated?
- Did the letter sent by Mr Jones to Mr Smith comply with the requirements of a Step 1 letter under the Standard Dismissal and Disciplinary Procedure?
- Did the decision to dismiss Mr Smith fall within the range of reasonable responses?
- Should Mr Smith’s compensatory award be reduced to reflect his contribution to his dismissal?
But always remember that the point of doing this is to make things easier, not to introduce a new source of potential confusion.
If your written submissions list a set of issues on page 2, then on page 11 you refer to ‘Issue 3’, there is a good chance that the person reading it will not remember what that issue is. They will have stop reading, break their train of thought, and flip back to page 2. Or they may press on, uncertain of what you are getting at, but hoping that it will become clear from what comes next. Neither of these possibilities is a good thing.
The solution is to refer to the nature of the issue as well as the number. For example:
Issue 3: Range of reasonable responses
Submissions arguing that dismissal fell outside the range of reasonable responses.