Ibid & Supra – Prior and Subsequent References to a Citation

Refer to E-1.4 of the McGill Guide.

The full citation is only used the first time you refer to a source. Subsequent citations use a short form, and ibid and supra to refer back to that initial citation.

General: Establishing a Short Form

When to create a short form: where a particular reference is used more than once in the work.

When a short form is not needed: 1) Where a reference is only used once in the work, do not create a short form. 2) If the title of a source is short (around three words or less), the full title may be used in all subsequent references (note exceptions to this general rule in sections below).

Placement: Whether in-text citations or footnotes, the first time you cite a particular source, place the italicized short title in brackets directly after the citation but before any parenthetical information and case history. Do not italicize the brackets.

For subsequent references: use the short title and appropriate cross-referencing signals (supraibid) to direct the reader back to the footnote containing the full citation (see ibid and supra categories below for more information on when to use them)

Examples:

1 Fisher v Fisher, 2008 ONCA 11 at paras 52-59 [Fisher].

2 Income Tax Act, RSC 1985, c 1 (5th Supp).

3 Rosas v Toca, 2018 BCCA 191 at para 3.

19 Fishersupra note 1 at para 30.

20 Income Tax Actsupra note 2, s 4(1).

note: do not include the short form in the bibliography or table of authorities of your work (unless, of course, its the official short title of a piece of legislation).

Short Form for Legislation

if a statute has an official short title, use only this short title in the initial citation. if the short title is brief, it may also be used in subsequent references.

Example:

Greater Vancouver Sewerage and Drainage District Act, SBC 1956, c 59.

note: for this example, the full title is An Act to Incorporate the Greater Vancouver Sewerage and Drainage District.

if a statute has no official short title, or if the official short title is too long for subsequent references, create a distinctive short title and indicate it in brackets at the end of the citation in italics. the brackets are not italicized.

Example:

Armoured Vehicle and After-Market Compartment Control Act, SBC 2010, c 8, s 12(5)[Armoured Vehicle Act].

well-recognized abbreviations may also be used.

Example:

Canada Business Corporations Act, RSC 1985, c C-44 [CBCA].

Note: abbreviations of codes such as CCQ are not considered short forms, and thus should not be italicised.

Short Form for Cases

Create a short form by choosing one of the parties’ surnames or a distinctive part of the style of cause

Example:

Rosas v Toca, 2018 BCCA 191 at para 3 [Rosas].

if appropriate, you may use other elements to identify the case:

  1. a more widely known style of cause from a lower court
  2. the name of a ship in admiralty cases (e.g. the Wagon Mound No 2)
  3. the name of the drug in pharmaceutical patent litigation (e.g. Viagra)

Where there are multiple cases with the same name: include the date of the decision for clarity. note that the date is not italicized.

Example:

R v Morgentaler, [1993] 3 SCR 462, 1993 CanLII 158 [Morgentaler 1993].

Where there are multiple decisions from the same case: use the court level abbreviations found in Appendix B-2 of the McGill Guide. note that the court abbreviation is not italicized.

Example:

Pappajohn v R, [1980] 2 SCR 120, 1980 CanLII 13 [Pappajohn SCC].
R v Pappajohn (1978), 45 CCC (2d) 67, [1979] 1 WWR 562 (BCCA) [Pappajohn CA].

Where the initial citation includes more than one source but contains no pinpoint reference: indicate the reporter to which subsequent pinpoint references will be made by including ‘cited to’ followed by the abbreviation of the reporter. This is done so that, in future citations of the same source that contain pinpoints, the reader knows which source you are pinpointing. Where the first citation contains a neutral citation or a pinpoint, do not do this.

Example:

5 R v Van der Peet, [1996] 2 SCR 507, 1996 CanLII 216 [Van der Peet cited to SCR]

future citations will look like this:

10 Van der Peet cited to SCR, supra note 5 at para 321.

Short Forms for Secondary Materials

General: Do not create a short form at the end of the first reference to the source. Only use the author’s surname in subsequent references to the source

Example:

1 Lynn A Idling, “In a Poor State: The Long Road to Human Rights Protection on the Basis of Social Condition” (2003) 41:2 Alta LR 513.

future citations will look like this:

3 Idlingsupra note 1 at 521.

Where you cite two or more authors with the same last name: include an initial for each, or several if appropriate.

Example:

6 Stephen A Smith, “Duties, Liabilities, and Damages” (2012) 125:7 Harv L Rev 1727.
10 Lionel Smith, “The Province of the Law of Restitution” (1992) 71:4 Can Bar Rev 672.
20 S Smith, supra note 6 at 1731.
21 L Smith, supra note 10 at 675.

Where more than one work by the same author is cited: create a short form consisting of the author’s name and a shortened form of the title of the work. In the short form of the title, maintain the same formatting as the full title-italics for books and quotation marks for articles.

Example:

Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392 at 340 [Hunt, “Downton Revisited”].

Chris Hunt, “Good Faith Performance in Canadian Contract Law” (2015) 74:1 Cambridge LJ 4 [Hunt, “Good Faith Performance Canada”].

Where two or more essays from the same collection: apply the same rules to create a short form for the collection, and then use that form in the first citation of each additional essay.

Ibid

Ibid is an abbreviation of the Latin word ibidem, meaning “in the same place”. Use ibid to direct the reader to the immediately preceding reference. Do not provide the number of the footnote in which the preceding reference appears.

Example:

5 Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392.

6 Ibid.

Where ibid may be used: Ibid may be used after a full citation, after a supra or even after another ibid.

Where there is more than one reference in the previous footnote: use supra instead of ibid as it may be confusing to the reader as to which reference you are referring.

An ibid used without a pinpoint reference refers to the same pinpoint as in the previous footnote. To cite the source as a whole, where the previous reference includes a pinpoint, use supra.

Example 1:

5 Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392 at 393.

6 Ibid.

Here, the ibid includes the pinpoint at page 393.

Example 2:

5 Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392 at 393.

6 Hunt, Supra.

Here, footnote 6 does not include the pinpoint used in footnote 5.

To refer to the previous source within the same footnote, use ibid in parentheses.

Example:

27 For a more detailed analysis, see Union des employés de service, Local 298 v Bibeault, [1988] 2 SCR 1048, 95 NR 161 [Bibeault cited to SCR]. The Court cited a “patently unreasonable” standard of review (ibid at 1084—85).

here, the ibid refers to the case highlighted in red.

Supra

Supra is the Latin word for “above”. Use the short form in combination with supra to refer to the footnote containing the original, full citation. Do not use supra to refer to either an ibid or another supra.

Example:

5 Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392 at 393.

6 Ibid.

10 Hunt, supra note 5.

Unlike ibid, supra always refers to the source alone and never implies reference to a pinpoint. Accordingly, reiterate the pinpoint even if the supra cites to the same passage as the original reference.

Example:

5 Chris Hunt, “Wilkinson v Downton Revisited” (2015) 74:3 Cambridge LJ 392 at 393.

10 Hunt, supra note 5 at 393.

If the source is clearly identified in the main text, it is unnecessary to re-identify that source in the footnote.

Example:

Body paragraph:

Rosas v Toca5 is a special case.

Footnote:

Supra note 3 at para 3.

To refer to both a previous footnote and the main text to which that footnote relates, use supra note # and accompanying text (see note 60). To refer only to the main text (rather than a footnote), use above rather than supra (section 1.4.4).

Example:

60 See also Faraggi, supra note 24 and accompanying text.

Above and Below

Use the words above and below to direct the reader to a portion of the main text and not to the footnotes.

Example:

See Part III-A, above, for more on this topic.
 Further discussion of this case will be found at 164—70, below.
If there are no easily identifiable section or paragraph markers, or if the final pagination of the text is unclear at the time of writing, use the formulation see the text accompanying note #.
Example:
For further analysis of the holding in Oakes, see the text accompanying note 41.
Design a site like this with WordPress.com
Get started
search previous next tag category expand menu location phone mail time cart zoom edit close