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Today, I will talk about three Latin terms you often find in judgments, legal articles, and academic writing:
- Supra
- Infra
- Ibid.
These terms are used to avoid repeating long references. Let's explore them one by one:
1. Supra = “See above” or “As mentioned earlier”
Used when you want to refer back to a source already cited earlier in the same document.
Example 1:
1. Indra Sawhney v. Union of India, AIR 1993 SC 477.
2. See Indra Sawhney (supra), at p. 485.
Example 2:
1. Kesavananda Bharati v. State of Kerala, AIR 1973 SC 1461.
2. See Kesavananda Bharati (supra), at p. 1500.
Example 3 (from a judgment):
In the State of Punjab v. Davinder Singh case, the petitioner argued that the sub-classification of castes, placed in the list of Scheduled Castes, is unconstitutional in view of the judgment of this Court in Chinnaiah (supra).
❌ Real Example of Incorrect Use of Supra in Legal Drafting
Recently, I received a notice from an advocate, which contained a misuse of the Latin legal term “supra.” Here's an anonymized excerpt:
Excerpt from the Notice (with sensitive details replaced):
“I, K. XYZ, Advocate, Owner of Villa bearing No. 123, ABC Enclave, constructed by ABC Constructions, am here by issue this notice for kind consideration and necessary action.
1. That you have issued a notice i.e., in the reference 1st cited supra informing the villa owners regarding the enhancement of maintenance charges.”
What’s wrong with this usage?
- The term “supra” is a technical citation tool used in legal documents, judgments, and scholarly articles to refer back to an earlier case, footnote, or source, usually in a format like:
“See Smith v. Jones, supra note 5.” - In the excerpt above, there's no formal reference or citation earlier in the document, so “1st cited supra” is grammatically and legally incorrect.
- This reflects a common mistake where legal terms are used just to sound formal, but end up reducing clarity and professionalism.
✅ Better Wording (Plain and Clear):
“That you have issued a notice, dated [insert date], informing the villa owners about the enhancement of maintenance charges.”
Takeaway for Legal Writers:
Avoid using “supra” unless:
- You’re referring back to a clearly numbered or footnoted citation, and
- The document is formal enough to warrant academic or judicial citation structure (such as court pleadings or research articles).
2. Infra = “See below” or “As mentioned later”
Used when referring to a source or point that will be cited or discussed later in the document.
Example 1:
The detailed analysis of the Mandal Commission’s findings is discussed infra, in Section 5.2.
Example 2:
The constitutional test for reasonable restrictions is discussed infra, in Part 4.3 of this paper.
3. Ibid. “In the same place” (from Latin ibidem)
Used when referring to the exact same source as the one immediately before, usually with the same page unless specified.
Example:
1. Kesavananda Bharati v. State of Kerala, AIR 1973 SC 1461, p. 1500.
2. Ibid.
3. Ibid., p. 1504.
- In citation 2, Ibid. means the same source and page as in citation 1.
- In citation 3, Ibid., p. 1504 means the same case as in citation 1, but now referring to a different page.
Summary Table:
| Term | Meaning | When to Use |
|---|---|---|
| Supra | See above | To refer to an earlier citation |
| Infra | See below | To refer to a later citation or section |
| Ibid. | In the same place | To refer to the immediately preceding source |
These small words carry big meaning in legal writing. Once you get used to them, you’ll notice how much more efficient and professional your citations can become.
Next in ‘Echoes of the Court’: One more term decoded....
......Anupama Singh
Read. Decode. Rule the room.
Writer: Anupam Singh | legal Blogger
The Legal Trifecta: IPR | Cyber Law | Property Law
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