McGill with Footnotes


For detailed examples of different types of McGill References, see the McGill: Examples & Applications page.


  • Statutes: Footnote the first instance of each statute in each chapter. Use a short form of the statute title for subsequent references in the chapter. Subsequent references do not need a footnote, unless there is reference to a specific section (i.e., a pinpoint reference), and the reference is not integrated into the running text.
  • [running text]
    The Mutual Legal Assistance in Criminal Matters Act (MLACMA)6 allows Canada to collect fines7...
    6 RSC 1985, c 30 (4th Supp) [MLACMA].
    7 MLACMA, s 9.

    In the following example, the Criminal Code has already been cited, and the section reference is in the text, so no footnote is needed.

    [running text]
    Section 684 of the Criminal Code states: “A court of appeal or a judge of that court may, at any time, assign counsel to act on behalf of an accused.”

    New as of June 23, 2017: Do not repeat case name in footnote unless the name is not mentioned in running text.

  • Case citations: Include only case citation in the footnote unless the case name is not mentioned in the running text.
  • [running text] ... the common law test established in Dagenais v Canadian Broadcasting Corp7 is used.
    [footnote] 7 [1994] 3 SCR 835, 94 CCC (3d) 289.
    [running text] ... unless the opposing party can satisfy the common law test established in Dagenais v Canadian Broadcasting Corp.22
    [footnote] 22 Supra note 7 at para 9.


Use ibid to refer the reader to an immediately preceding reference. Use only if the antecedent is very clear. That is, if there’s only a single reference in the antecedent footnote. If there is more than one, use supra.

If subsequent references contain a pinpoint, the first reference should specify which source is being cited (that is, which source the pinpoints are being taken from).

[running text]
However, given the Supreme Court of Canada’s pronouncement in St-Cloud10 that an .... Wagner J held “he or she might take account of the fact that the trial of the accused will be held at a much later date.”11
10 2015 SCC 27, [2015] 2 SCR 328 [St-Cloud cited to SCC]. 11 Ibid at para 71.

Use supra to refer the reader to a reference containing the original, complete citation. Repeat the case or source name if it’s not mentioned in the running text, or if there is more than one citation in the note to which the reader is being referred. In the first example, even though Toronto Star Newspapers Ltd v Canada is mentioned in the preceding note, an ibid reference might cause confusion because there are two citations in the preceding note. The case name is repeated for clarity as well. In the second example, there’s no need to repeat the case name because it is mentioned in the running text.

[running text]
Section 517 was held to be a justifiable limit on the right to freedom of expression guaranteed by section 2(b) of the Canadian Charter of Rights and Freedoms.18 The pressing and substantial objectives of section 517 are to safeguard the right to a fair trial and to ensure expeditious bail hearings.19     [footnotes]
18 Toronto Star Newspapers Ltd v Canada, 2010 SCC 21, [2010] 1 SCR 721 at para 61; Canadian Charter of Rights and Freedoms, Part I of the Constitution Act, 1982, being Schedule B to the Canada Act 1982 (UK), 1982, c 11 [Charter].
19 Toronto Star Newspapers Ltd v Canada, supra note 18 at para 23.
[running text]
... an obligation to be full, fair, and frank in the application.13... have the extradition proceedings stayed, as was argued in Tollman.47     [footnotes]
13 USA v Tollman (2006), 271 DLR (4th) 578 at para 135 (Sup Ct J).
47 Supra note 13 at para 140.

Use infra to refer the reader to a subsequent reference. Not very common, but used when a case is first mentioned simply in passing, and is discussed more fully later on in the text. An “infra” reference can be used at the first mention.

[running text]
An additional reason to undertake such a process is to cause the immediate cessation of any offensive behaviour.2
2 As in Harriott v National Money Mart, infra note 15.
    [running text; later in chapter]
The HRTO made a similar finding of a failure to properly investigate in the case of Harriott v National Money Mart.15
15 Harriott v National Money Mart, 2010 HRTO 353.




1 R v Brydges, [1990] 1 SCR 190, 53 CCC (3d) 330.

2 Human Rights Code, RSO 1990, c H.19.

3 Criminal Code, RSC 1985, c C-46, s 672.76(2)(a.1).

4 D Buckley & B Jayne, Electronic Recording of Interrogations (Eagle River, Wis: Hahn, 2009).

5 AW Bryant, SN Lederman & MK Fuerst, The Law of Evidence in Canada, 3rd ed (Toronto: LexisNexis Canada, 2009).

6 Janice Johnston, “Mark Lindsay Confession Came After Hours of Interrogation,” CBC News (21 February 2016), online:

7 R v LF, 2006 CanLII 4903 at para 10 (Ont Sup Ct J) .

8 R v Elliott (2003), 181 CCC (3d) 118, 2003 CanLII 24447 (Ont CA) .

9 R v Brydges, supra note 1.

10 Bryant, Lederman & Fuerst, supra note 5 at 123.

11 Ibid at 124-25.