How to name annexures: the pleaded-title rule

At midnight the folder says IMG_4021.pdf, letter final FINAL (2).pdf and scan0003.pdf. None of that matters, and none of it ever has to be fixed. The only name an annexure needs is the one your pleading gives it — and that name, once pleaded, governs everything that follows.

The rule, stated

The title you plead in the body of the draft is the annexure's title everywhere else. On the index. On the label that opens the annexure. On the bookmark in the e-file. Verbatim — not paraphrased, not shortened, not improved. One document, one name, repeated exactly wherever the record refers to it.

The pleading is the master; every other surface is a copy of it. The moment an index entry drifts from the pleaded title — a reworded description, a dropped date — the reader has to stop and ask whether it is the same document. In a filing, a reader who has to ask is a reader you have lost.

Why the pleading wins

Whoever takes up your filing reads it against the pleading. A judge or arbitrator meets the annexure first in your paragraph — "the letter dated 14.03.2020, annexed as Annexure C-7" — and then goes looking for C-7 in the record. If the index calls C-7 something else, or the bookmark carries a stray abbreviation, the thread between argument and evidence frays exactly where you need it strongest.

Bookmarks raise the stakes further. In an e-filed or soft-copy record, the bookmark panel is the index the reader actually uses. A bookmark that repeats the pleaded title takes the reader from your paragraph to the page in one motion. A bookmark that improvises does not.

Writing a title that does its work

A pleaded title carries three things: the instrument, the parties, and the date — the date as it appears on the face of the document, not from memory.

Letter dated 14.03.2020 from the Claimant to the Respondent
Supplementary Agreement dated 27.07.2020 between the parties
Invoice no. 118 dated 03.02.2021 raised by the Petitioner

Keep it to one line. Name the instrument precisely — a "Supplementary Agreement" is not a "document", and a "reminder letter" earns its adjective only if the face supports it. This titling is lawyering, and it stays yours: the polished title is counsel's judgment about what the document is and why it is there.

Numbering: 31 is just 31

Sequence follows the pleading too. Annexures run in the order the draft pleads them — P-1, P-2 or C-1, C-2 — with no gaps and no inventions. Resist the midnight temptation to slip a late document in as 31A between 31 and 32: interpolated numbering on a fresh filing is a known objection, and registries have refused it outright. If a document surfaces after the draft is settled, the cure is upstream — re-sequence in the draft, then assemble. Lettered annexures that already exist on a filed record are a different matter: there, C-31A stays C-31A, verbatim, because the record has already spoken.

What AIC does with your titles

Send the drafted pleading and the annexure folder as it sits. AIC reads the draft, mines every pleaded title in sequence, then matches each badly-named file to the annexure you pleaded and renames it to your exact title — index, label and bookmark all carrying the same words, because they are all copies of your pleading. And while it matches, it verifies: the date and parties on each document's face are set against what you pleaded, and anything that doesn't sit comes back as one line on a check-sheet, for your call. We flag; we never edit.

The title is counsel's work. Carrying it faithfully through every surface of the paperbook is the clerk's. The clerk, not counsel — with files kept read-only, processed on our own machines, deleted on completion.

Questions litigators ask

Do I need to rename my files before sending them?

No. The folder can arrive exactly as it sits — photos, scans, FINAL (2) and all. The draft already did the organising; matching the mess to it is the clerk's trade.

Two files in my folder could both be the same annexure. What happens?

The pairing is never guessed silently. Where a match is uncertain, both candidates are shown against the pleaded title and the point is flagged for your decision before assembly.

The date in my pleaded title doesn't match the date on the document's face. Do you correct it?

No. The divergence goes on the check-sheet — draft says one date, face shows another, page cited — and your draft stays untouched. We flag; we never edit. Which one is right is a call only counsel can make.

What about lettered annexures like C-31A?

Kept verbatim when a filed record already uses them — existing lettering is never renumbered. On a fresh filing, no letter-suffixes are invented: the sequence is cured in the draft before the book is built.