THE IMPORTANCE OF LEGAL CITATION

Legal research and advocacy relies very heavily on citation. For the purposes of first year law school, citation focuses primarily on cases, although statute, article and book citation are relevant as well. Case citation serves two major functions: first, a complete citation allows the reader to find the decision; second, it should convey valuable information about the case, including the date it was handed down, court level, jurisdiction and case history (if included). Accurate citation provides a road map which directs the reader to where to locate the law. As with an actual road map, users of citations depend on their accuracy. Inaccurate or incomplete citations will result in people taking a detour from their goal and wasting time in their legal research.

 This chapter is intended to provide an introduction to the citation of:

o        Cases
o        Statutes and Regulations
o        Books and Journal Articles
o        Internet documents

Under each of these headings, you will find an explanation and detailed breakdown of how to construct a citation, followed by a series of examples. It is important that you take the time to understand and follow these steps to correct citation.

McGILL GUIDE: THE CANADIAN GUIDE TO UNIFORM LEGAL CITATION

The Canadian Guide to Uniform Legal Citation, 6th ed. (Toronto: Carswell, 2006), a.k.a. the "McGill Guide," was created in an effort to standardize Canadian legal citation and provide a nationally acceptable reference system. The guide has been adopted as the authority on legal citation by the majority of Canadian legal publications including the Queen's Law Journal. The McGill Guide is an excellent resource which contains detailed citation information. In addition to specific explanations and examples, the guide contains appendices which include helpful lists of abbreviations and other useful information about citations. This chapter is intended to provide an introduction to citation only and it is recommended that for the clarification of any finer or detailed points, the guide itself, which is the official authority on citation in Canada, be consulted.

CITING CASES 

The citation is a valuable and concise source of information which includes the name of the parties involved in the action, the date the decision was handed down, the jurisdiction and the court in which the case was heard. It also provides information on where a specific case may be found--i.e., in what reporter(s) the case in its entirety is located. Lawyers use cases to make claims about the strength of their own cases and about the law itself, and other legal professionals--judges, clerks, opposing counsel--are required to determine whether those claims are accurate by finding and reading those cases. As a result, legal professionals are expected to know how to cite cases correctly--the inability to do so can damage one's credibility.

How Does One Cite A Case? - Building The Citation 

The following is the standard formula for properly citing a case in Canada:

 This is how a citation will typically appear:

Hopp v. Lepp, [1980] 2 S.C.R. 192.

Clearbrook Iron Works Ltd. v. Letourneau, 2006 FCA 42, 46 C.P.R. (4th) 241.

Let's break down and examine each part of the cite to understand how it is constructed:

A. Style of Cause

• a case is identified by the names of those who were parties to the litigation
• in general, one uses only the last name of the first mentioned party on each side, e.g. "John Smith et al. v. Mary Jones" becomes Smith v. Jones
• "v." is an abbreviation for versus and is pronounced "and" in civil cases
• the names of the parties and the "v" are italicized
  
  

  example: Hopp v. Lepp

Note:

"Indexed as": for recent cases, an "indexed as" title will appear at the beginning of a case. If you are ever in doubt as to what the style of cause for a case should be, this is a useful bit of information. Check the first page of the judgment and if the case has an "indexed as" reference, use it for citation purposes.

Reference to the Crown: As an element of constitutional monarchy, Canadian executive government authority is formally vested in the Queen, hence the use of "R." for the Latin word for queen, regina, in legal citations. This is used mainly for criminal cases prosecuted by the state, although you may also see R. as part of a citation for a civil case, in place of such terms as "The Queen", "The Queen in right of," etc.

examples: R. v. Smith (criminal case brought by the Crown) Smith v. R. (a private case brought against the State)

If the specific government department or agency that is involved in the civil litigation is known, use it rather than "R."

example:             Buckman v. M.N.R. (The Minister of National Revenue is the government agent involved)

B. Neutral Citation

Since 1999, many Canadian courts have begun assigning neutral citations to their judgments. If your decision has a neutral citation, you must cite to it first and then to a printed reporter. Both are required, as the neutral citation is only a case identifier and does not indicate where a case can be found. It consists of three parts:

• year of decision
• abbreviation of the court
• an ordinal number

For example, Lovelace v. Ontario has the neutral citation 2000 SCC 37:

Year of decision	Court	Ordinal Number
2000	SCC	37
	Supreme Court of Canada	37th case decided in 2000

Because the neutral citation indicates the year of the decision, the court, and court level, these elements should be omitted from the rest of the citation.

• the year in which the case is decided (and/or published) follows the style of cause and must be in brackets.
• the brackets will either be round for year of decision or square for reporter volume designation.
• Round brackets are used when the reporter volume numbering is continuous from year to year.
  
  

  example: R. v. Carosella (1995), 26 O.R. (3d) 209 (C.A.).

• Square brackets are used to indicate that the law reporter numbers its volumes within the calendar year. For such reporters, the date becomes integral to the volume numbering. This system is less common but it is important to note that the Canada Supreme Court Reports (S.C.R.) uses this method.
  
  

  Example: Hopp v. Lepp, [1980] 2 S.C.R. 192. (note that the comma follows directly after the style of cause)

  
  
• When there is a neutral citation, no date is needed after the style of cause because the neutral citation includes the date (see example 1). However, the reporter series may still require a date in square brackets, as in the second example.
  
  

  Example 1: Clearbrook Iron Works Ltd. v. Letourneau, 2006 FCA 42, 46 C.P.R. (4th) 241.

  Example 2: R. v. Kang-Brown, 2008 SCC 18, [2008] 1 S.C.R. 456.

Note:

• Round brackets refer to the date the reasons for judgment were handed down.
• Square brackets refer to the date on the spine of the reporter (the date of publication).
• a comma follows round brackets but comes before square brackets
  
  

  example: Swiss Bank Corp. v. Air Canada, [1988] 1 F.C. 71.

While this case is reported in the 1988 Canada Federal Court Reports, the decision was actually handed down in 1987. This requires both years to be included in the citation, as in the example:

Swiss Bank Corp. v. Air Canada (1987), [1988] 1 F.C. 71. The round brackets clarify that the decision was handed down in 1987. The square brackets refer to the law report volume in which the case appears.

In most cases, the year of publication coincides with the year the decision was handed down. Sometimes, however, there is a time lag between when a case was decided and when it was reported. Be aware that it is possible for a 1987 case to appear in a 1988 court reporter. To be sure of the year of the decision, look at the first page of the case itself.

D . Law Report Volume Number

As indicated above, there are two ways a reporter series may be numbered:

• consecutive volume numbers are used by the majority of series and simply begin at volume one and continue on indefinitely
  
  

  example: Ontario Hydro v. Ontario (Labour Relations Board) (1993), 107 D.L.R. (4th) 457 (S.C.C.) (This citation indicates that the case will be found in volume 107 of the fourth series of the Dominion Law Reports at page 457. The date is not integral to locating the case.)

  
  
• volume designated first by year, then by volume within the year is the second possibility which requires the use of SQUARE BRACKETS; there is a new sequence of volume numbers which begins with each year
  
  

  example: Ontario v. Ontario (Labour Relations Board), [1993] 3 S.C.R. 327. (This citation indicates that the case can be found in volume 3 of the 1993 volumes of the Supreme Court Reports at page 327. The date is critical to locating the case.)

E . Law Reporter Abbreviation

• A law reporter is always referred to in the citation by a standard abbreviation of its title.
• There are a great many court reporters. It is not necessary to memorize the abbreviations for each; the McGill Guide provides a list of reporter names and abbreviations used for citation purposes in Canada. For more information, see the section on Finding Abbreviations for Law Reports and Journals.
• The reporter series number is also abbreviated and placed in brackets directly following the report title. The abbreviations used are (2d), (3d), (4th), (5th) and so on. The series numbers should not be in superscript.
• Note that (2d) and (3d) are used in lieu of (2^nd) and (3^rd).
  
  

  example: Masson v. Kelly (1991), 85 D.L.R. (4th) 214 (Ont. C.A.). (This case can be found in volume 85 of the fourth series of Dominion Law Reports.)

F . Court

• As a general rule, one must always be able to discern both the jurisdiction and court level from the citation. This information will either be implicit in the neutral citation, the title of the law reporter, or expressly indicated in round brackets at the end of the citation.
  
  
  

  examples: R. v. Carosella (1995), 26 O.R. (3d) 209 (C.A.). (In this case, it is obvious from the court reporter that the decision was handed down by the Ontario Court of Appeal. Had this not been obvious, the court level would have read (Ont. C.A.)) Hopp v. Lepp, [1980] 2 S.C.R. 192. (Implicit in the reporter title is the information that this case was heard by the Supreme Court of Canada. As a result, it is not necessary to list the court in brackets at the end of the citation.) Clearbrook Iron Works Ltd. v. Letourneau, 2006 FCA 42, 46 C.P.R. (4th) 241. (The neutral citation indicates that the case was heard at the Federal Court of Appeal, so no court information at the end of the citation is needed.)

G . Parallel Citations

• Cases may be reported in several different series, and there is no way of knowing which reporter any given reader will be able to access. For this reason parallel citations are used.
• A parallel citation simply provides "directions" to other locations where the relevant case may be found.
• Canadian law reporters are ranked in status as either official, semi-official or unofficial. When including parallel citations, arrange these in order from the most official to least official versions. When citing, use official and semiofficial sources before an unofficial source. Refer to the McGill Guide's list of reporter status in Appendix G for more detailed information.
  
  

  Example: R. v. Carosella, [1997] 1 S.C.R. 80, 142 D.L.R. (4th) 595, 112 C.C.C. (3d) 289. (This case can be located in the Supreme Court Reports, Dominion Law Reports or Canadian Criminal Cases) Note:  S.C.R. is an official reporter.

H. Case History

• When a case has gone through more than one court level, it may be relevant to reference the complete case history.
• While it is possible to begin a citation with any decision, the conventional method is to cite either the final or initial court level and list each decision sequentially from there.
• When citing in the order of highest to lowest court level, use the abbreviations aff'g (affirming) and rev'g (reversing) to indicate the prior history of the case.
  
  

  R. v. Carosella, [1997] 1 S.C.R. 80, rev'g (1995), 26 OR (3d) 209 (C.A.), aff'g (1994), 25 C.R. (4th) 301 (G.D.). Note: The rev'g or aff'g refers  to the Supreme Court's action in relation to both of the lower level decisions.

Case Citation Examples

We have examined the individual components of a legal citation. The annotations following the examples below consider what information is being conveyed in each citation and how you should be able to find each case.

Example #1:	Queen v. Cognos Inc., [1993] 1 S.C.R. 87. This citation indicates that the Queen v. Cognos case was reported in volume 1 of the 1993 Canada Supreme Court Reports, beginning at page 87. The fact that it appears in this reporter indicates that the decision was rendered by the Supreme Court of Canada.
Example #2:	Queen v. Cognos Inc. (1993), 99 D.L.R. (4th) 626 (S.C.C.). This citation indicates that Queen v. Cognos can also be found in volume 99 of the fourth Series of the Dominion Law Reports, beginning at page 626, and that it is a decision of the Supreme Court of Canada.
Example #3:	Queen v. Cognos Inc., [1993] 1 S.C.R. 87, 99 D.L.R. (4th) 626, 14 C.C.L.T. (2d) 113. This citation indicates that Queen v. Cognos is reported in the Canada Supreme Court Reports, the Dominion Law Reports (4th series), and also in Canadian Cases on the Law of Torts (2d series). It must have been a decision of the Supreme Court of Canada since the first citation is to the S.C.R.
Example #4:	Queen v. Cognos Inc. (1990), 74 O.R. (2d) 176 (C.A.). This citation indicates that the Ontario Court of Appeal made a decision in the Queen v. Cognos dispute, in 1990, and the case can be found in volume 74 of the Ontario Reports (2d series), at page 176.
Example #5:	Queen v. Cognos Inc., [1993] 1 S.C.R. 87, 99 D.L.R. (4th) 626, 14 C.C.L.T. (2d) 113, rev'g (1990), 74 O.R. (2d) 176, 69 D.L.R. (4th) 288 (C.A.), aff'g (1987), 63 O.R. (2d) 389 (H.C.J.). This citation indicates that the 1993 decision from the Supreme Court of Canada reversed the 1990 decision from the Ontario Court of Appeal, but affirmed the 1987 decision of the Ontario High Court of Justice. The most recent decision is reported in 3 different law report series: the first appeal decision is reported in 2 different series, and the trial level decision was only reported in one law report series, the Ontario Reports (2d series). The square brackets in this citation refer to the date upon the spine of the reporter where the case is located. The dates in round brackets tell us the actual dates those decisions were handed down.
Example #6:	Lucas v. Antoniak (1978), 7 C.C.L.T. 209 (B.C.S.C.), aff'd (1980), 15 C.C.L.T. 195 (C.A.). Leave to appeal refused (1981), 15 C.C.L.T. 195n., 36 N.R. 447 (S.C.C.).  This citation indicates the 1978 decision of the British Columbia Supreme Court was affirmed by a 1980 decision of the B.C. Court of Appeal (which is reported in volume 15 of Canadian Cases on the Law of Torts). Leave to appeal was refused by the Supreme Court of Canada in 1981; this decision can be found in the C.C.L.T. and the National Reporter (N.R.)

Citing Cases From Electronic Databases

• Only cite a case using a LexisNexis Quicklaw, Westlaw Canada, or CanLII identifier in the event that it does not have a citation to a print reporter. If a print citation exists, it should be used.
• If the case has not been reported in a print reporter, use the neutral citation (if there is one) in preference to the database's own identifier.

Example #1: neutral citation available

R. v Bajwa, 2007 BCCA 181 (WL Canada). This case was not reported in any print reporters. It had a case identifier assigned by Westlaw Canada, but this was omitted, as it also had a neutral citation. The date, court and court level (British Columbia Court of Appeal) are apparent from the neutral citation, so those elements do not need to be added to the citation. The "WL Canada" indicates that the case was retrieved from Westlaw Canada.

Example #2: no neutral citation available

Bank of Nova Scotia v. Visentin, [1996] O.J. No. 4563 (Gen. Div.) (QL). This case was not reported in any print reporters, and it has no neutral citation. Therefore, it is cited to the case identifier assigned by LexisNexis Quicklaw. The "O.J." indicates that it is a case from Ontario but does not indicate the court level; therefore, the "Gen. Div." is needed at the end. Finally, the "QL" shows that the case was retrieved from LexisNexis Quicklaw.

Citing Cases From Electronic Databases: Examples

 Here are a few examples to look over. Try to identify and understand each part of the citation.

Example #1: (LexisNexis Quicklaw)	R. v. Butler, [1992] S.C.J. No. 15 (QL). Note that it is not necessary to include the court because it is clear from the database that this case was handed down by the Supreme Court.
Example #2: (LexisNexis Quicklaw)	R. v. Howard, [1991] A.J. No. 1025 (C.A.) (QL). Here, it is evident that the case was decided in Alberta (database abbreviation A.J.), but it is unclear which court heard the case, so the abbreviation must be included.
Example #3: (Westlaw Canada)	Harris v. Beck Estate, 2007 CarswellPEI 11 (S.C.(T.D.)). The identifier shows the case is from P.E.I. but does not indicate the court; therefore, the court abbreviation had to be added. The identifier also indicates it's from Westlaw Canada, so there is no need to add that information at the end.
Example #4: (CanLII)	O.E.X. Electromagnetic Inc. v. Coopers, 1991 CanLII 1336 (B.C. S.C.). The only additional information needed is the court and jurisdiction; the identifier gives the year and electronic database information.

CITING CASES ON THE INTERNET

Legal materials , including full text cases and statutes, are often available for free on the internet (as opposed to through subscription services requiring passwords). It is always better to cite a case to a printed reporter, or a database, than simply to an online document. However, when it is your only option, the McGill Guide offers direction as to the proper citation for electronic materials.

Where the case has not been reported, use style of cause, date, court location and docket number (if unreported), court abbreviation, the designation "online:" followed by name of the host organization and the internet address in angle brackets, followed by a period.

Butler v. Nenqayni Treatment Centre Society (28 October 2002) CHRT D.T. 12/02, online: CanLII <http://www.iijcan.ca/ca/cas/chrt/2002/2002chrt10001.html>.

 

CITING UNREPORTED CASES

Cases published in law reporters are chosen because of their relevance in expanding on or clarifying a point of law and, as a result, many cases remain "unreported". Unreported cases are sometimes available through an electronic sources such as LexisNexis Quicklaw, Westlaw Canada, or CanLII. Where a case is not available electronically, however, it must be accessed directly from the court that handed down the decision. To cite such a case, use the following form: Style of cause, date of decision, judicial centre, docket number, jurisdiction and court level. Here is an example:

Stephenson v. Stephenson (6 December 1984), Nanaimo 5920/004143 (B.C.S.C.).

PINPOINT REFERENCES

A pinpoint reference refers to a specific part of a document discussed. This reference is placed at the very end of the citation. If the case's paragraphs are numbered, cite to the paragraph. Otherwise, cite to the page. "Paragraph" is abbreviated to "para." "Page" is not used; if there is no abbreviation before the number, it is understood to be indicating a page.

Example: Masson v. Kelly (1991), 85 D.L.R. (4th) 214 (Ont. C.A.) at 225. R. v. Latimer, [1997] 1 S.C.R. 217 at para. 27.

CITING STATUTES AND REGULATIONS

Often you will need to refer to legislation in your legal writing. Citation of statutes and regulations is very straightforward and will take the following form:

This is how a typical citation of a statute or regulation will appear:

Fewer Politicians Act, S.O. 1996, c. 28.

Citation Breakdown:

A. Short Title

• Most statutes have lengthy titles; to save time and space the "short title" is acceptable for citation purposes.
• This title is easy to find at either the beginning or end of the act and will be prefaced by the words, "This act may be cited as". Use the short title designated and remember to italicize it.

B. Volume Title Abbreviation

• Revised Statutes or Regulations: Periodically the federal and provincial governments publish consolidations of all the statutes or regulations in force in their respective jurisdictions as of a particular date. These are referred to as the Revised Statutes or the Revised Regulations and are cited as follows: 

R.S.O. 1990 ­ this stands for the Revised Statutes of Ontario 1990

R.S.C. 1985 ­ this stands for the Revised Statutes of Canada 1985

examples: Employment Standards Act, R.S.O. 1990, c. E.14. Canada Elections Act, R.S.C. 1985, c. E-2.

• Annual statutes: Between the publication of Revised Statutes, annual statute volumes are published. These contain both new and amending statutes which have received Royal Assent during the past year. These updates are cited as follows:

S.O. 1991 (Statutes of Ontario 1991)

S.C. 1991 (Statutes of Canada 1991)

example: Arbitration Act, 1991, S.O. 1991, c. 17. Note that the year is included with the volume title abbreviation.

C. Chapter Number

• This element of the citation refers to the specific chapter number which the statute has been assigned in the volume.

D. Section Number

• If necessary, include a reference to the section(s) of the statute you are discussing. This is known as a "pinpoint reference".

Notes:

• Some provinces also publish statutes in loose-leaf format. Often the loose-leaf version does not have official status. See the McGill Guide.
• Sessional volumes: In the past, bound volumes of Federal and Ontario statutes were published at the end of each legislative session, rather than on a calendar year basis.
  
  

Revised Statutes which have been amended:

It is only necessary to include a reference to an amending statute in the citation if it is relevant to a point being discussed. To include an amending statute, cite the original statute first, followed by "as am. by" and the citation of the new act. Include the name of the amending statute only if it differs from the original act.

Examples: Employment Standards Act, R.S.O. 1990, c. E.14, as am. by S.O. 1991, c. 16 and S.O. 1991, c. 43, s. 2. This citation refers to the Employment Standards Act, chapter E.14 which has been amended by two different 1991 statutes, chapter 16 and chapter 43, s. 2. Hay and Straw Inspection Act, R.S.C. 1985, c. H-2, as am. by S.C. 1994, c.38. This citation is referring to federal legislation, the Hay and Straw Inspection Act, chapter H-2 in the 1985 revised statutes, which has been amended by chapter 38 of the 1994 statutes.

Note on Regulations:

Regulations are passed under the authority of a particular statute at either the federal or provincial level.

Example of federal regulations:

Competition Tribunal Rules, SOR/87-373.

• SOR is the abbreviation for Federal "Statutory Orders and Regulations", followed by the last two digits of the year number in which it was passed and the regulation number.

Example of provincial regulation:

O. Reg. 45/91.

• When citing an Ontario regulation, the regulation number is listed first followed by the last two digits of the year in which the regulation was passed. These citations do not include the name of the regulation, so it is imperative to refer to the Act the regulation was made under to provide context for the citation. For example, one might include in the text a comment such as: Regulation 45, made under the Ontario Drug Benefit Act.

Pinpoints

When citing statutes and regulations, a pinpoint reference will refer to a specific section number within the legislation. The pinpoint appears at the end of the citation. Consider the following examples:

Judges Act, R.S.C. 1985, c.J-1, s.4.

Indian Act, R.S.C. 1985, c. I-5, ss.10(a), 12, 17-20.

Note that "section" is abbreviated to "s." and "sections" is abbreviated to "ss." Unlike books and journal articles, there is no "at."

CITING BOOKS AND JOURNAL ARTICLES

Books

As with legal publication, citing books and journal literature also requires care and attention to detail. Locating such a secondary source may be just as important to the reader as finding a case or piece of legislation. A proper legal book citation conforms to the following standard:

name of author, title, edition statement, place of publication, publisher, year of publication

This is how a typical book citation will appear:

S.M. Waddams, The Law of Contracts, 3d ed. (Toronto: Canada Law Book, 1993).

Citation Breakdown:

A. Author's Name

• initial(s) or first name, then last name  

B. Book Title

• the title is always in italics (or underlined)

C. Edition Number

• include if this is not the first edition (note that 2d and 3d are used, not 2^nd and 3^rd)

D. Place of Publication

• the city name is followed by a colon and contained in parentheses along with the publisher name and year of publication 

E. Publisher

F. Year of Publication

Note that all book citations are concluded with a period 

example: P.W. Hogg, Constitutional Law of Canada, 2d ed. (Toronto: Carswell, 1985).

 

Journal Articles

The formula for citing journal articles is similar to citing books:

Typical citation of a journal article:

P. Hughes, "Women, Sexual Abuse by Professionals, and the Law: Changing Parameters" (1996) 21 Queen's L.J. 297.

Citation Breakdown:

A. Author's Name

• initial(s) or first name then last name followed by a comma

B. Article Title

• the title of the article is placed in quotation marks

C. Year

• the year is always contained in round brackets

D. Volume and Issue Number

• only include the issue number if the page numbers restart at "1" for each issue.
• If using an issue number, it follows the volume number with a colon, e.g. 25:4 (volume 25, issue 4).

E. Journal or Review

• use the proper abbreviation for the journal. Refer to the McGill Guide Appendix D for a list of periodical abbreviations. For more information, consult the section on Finding Abbreviations for Law Reports and Journals.

F. Page Number

• this number refers to the first page of the article within the journal
  
  

  example: P. Monture, "A Vicious Circle: Child Welfare and the First Nations" (1989) 3 C.J.W.L. 1.

PINPOINTS

Pinpoint to a page or section. See the following examples:

Books

P.W. Hogg, Constitutional Law of Canada, 2nd ed. (Toronto: Carswell, 1985) at 73.

R.J. Delisle, Evidence: Principles and Problems (Toronto: Carswell, 1984) at 129.

Journal Articles

M.G. Bridge, "Discharge for Breach of the Contract of Sale of Goods" (1985) 28 McGill L.J. 867 at 913.

Citing Internet Documents

Cite to the traditional citation - whether it is an article, a government document, etc. - followed by a comma, "online:", the name of the website, and the URL. For example:

Polly Donda-Kaplan & Natasha Bakht, The Application of Religious Law in Family Law Arbitration Across Canada, online: Women's Legal Education and Action Fund <http://www.leaf.ca/Paper_The_%20Application_of_Religious_Law_In_Familiy_Law_Arbitration_Across_Canada.pdf>.

Finding Abbreviations to Law Reports and Journals

Sometimes you need to find what a particular abbreviation stands for in order to track down the reporter or journal, and other times, you might want to cite something but not be sure of the correct abbreviation to use. When in doubt, consult the following:

Canadian Guide to Uniform Legal Citation, 6th ed. (Toronto: Carswell, 2006).
Call number: Ref. or Reserve KE259.C35 2006

Canadian Abridgment - note that there is a list of abbreviations at the front of each volume.

British:

Donald Raistrick, Index to Legal Citations and Abbreviations, 3d ed. (London: Sweet & Maxwell, 1993).
Call number: Ref. KD400.R35 2008

American:

Mary Miles Prince, Bieber's Dictionary of Legal Abbreviations, 5th ed. (Buffalo: W.S. Hein, 2001).
Call number: Ref. KF246 .B46 2001

Online:

Cardiff Index to Legal Abbreviations