Answered By: Jonathan Faerber (he/him/his)
Last Updated: Nov 03, 2023     Views: 5635

Once a footnote introduces a citation for a legal resource (see "1" below), the italicized words "ibid" (standing for “ibidem” or “in the same place” in Latin) or “supra” (meaning “above” in Latin) in subsequent footnotes indicate a repeated citation to a source (McGill Law Journal, 2023, E-11). The abbreviation "ibid" on its own repeats the entire citation in the subsequent footnote, including the exact pinpoint included in the preceding footnote, as in "2" below (McGill Law Journal, 2023, E-12). By contrast, “ibid” combined with a new location of cited material repeats the citation with an additional pinpoint (see "3" below):

1. Criminal Code, 1985 RSC, c C-46 ss 293298.

2. Ibid

3. Ibid at 295(2)(3).

Rather than repeating the original citation from a previous footnote, the word "supra" combined with a title in a footnote refers to the first citation contained in a document including that title, with each "supra" footnote  containing the pinpoint for the specific location of material cited in text (McGill Law Journal, 2023, E-12). For instance, rather than repeating the original, full citation from "4" below, the title combined with the word supra in "5" below refers to the case introduced in the original citation contained in "4":

4. R v Morgentaler, 1988 CanLII 90 (SCC)

5. R v Morgentaler, supra at 3435.

Occasionally, when the main title of a case or legislation is longer than three words, a short title in italics and square brackets after the first citation (see "6") creates an abbreviated format for the case. Combing this shorter title of the case with supra in a repeated citation refers to the full title in the original citation, as in "7" below:

6. Tsilhqot'in Nation v British Columbia, 2014 SCC 44 at 260 [Tsilhqot'in].

7. Tsilhqot'in, supra at 262.

For more information on referring to a specific location in the source (e.g., when citing quoted or paraphrased text), please also see What is a Pinpoint, and How is it Used in a Legal Citation? and please refer to the information in the Writing Centre's Legal Citation Guide for an introduction to the McGill Guide (10th ed.) rules for legal citations.

Reference

McGill Law Journal. (2023). Canadian guide to uniform legal citation (10th ed.). Thomson Reuters.