The paper the Bombay High Court actually reads

Most papers fail before the law is reached. A date is missing, the annexure is not the document the paragraph cites, or the proposition is buried under grievance. This note is about the discipline of a paper on the Civil Appellate Side. It is not a precedent. It is the order in which a reader, with a board of such papers, can find the point.

The proposition, in one place

State, near the front, the rule you say has been broken and the precise relief. A sentence that the petitioner is aggrieved is not a proposition. A proposition names the duty, the order, and its date. If that cannot be written in a short paragraph, the draft is not ready to file.

The list of dates is the argument, in order

• Every date that matters, and no date that does not. A list of dates is not a diary.
• Against each date, one fact. The submission belongs in the petition, not in the list.
• The date of the impugned order has to be impossible to miss.
• Annexures follow the same order, are paginated, and are referred to by that page.
• An illegible page is not part of the compilation, however important it felt when it was scanned.

Urgency has to be urgent

A circulation request which says only that the petitioner is suffering reads like every other request. State the date on which something irreversible happens: a demolition, a taking of possession, a hearing before the authority, the last day of a limitation. If nothing irreversible is dated, the listing is ordinary. Inflated urgency is remembered the next time.

What not to hide

Do not leave the only copy of the show-cause notice in an annexure and forget to plead its date. Do not exhibit a photograph without saying when it was taken. Do not quote a judgment you have not opened. Two authorities you can defend are more than five a tool suggested. And do not describe this note, or any educational page, as the law. The law is in the statute and in the judgment. The paper’s job is to let the court find both without a search.