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Repeat References: Above n and At

How to cite a source the second time. There is no ibid in New Zealand.

The first footnote for a source gives it in full. After that you shorten it, and the Style Guide gives you two ways to do that (r 2.3.1(a)).

Which one you use depends on a single question: can the reader already tell which source you mean?

There is no ibid

This is the first thing to unlearn if you have used another style. The Style Guide does not use ibid, and r 2.3.1(a) says so in terms. If you write it in a New Zealand paper it is wrong.

What replaces it is a bare reference to the pinpoint alone.

When the source is obvious: the bare reference

Where the text or the footnote immediately above makes it clear which source you mean, the whole footnote is just the pinpoint.

It opens with a capital letter and the designation is written out in full, because the reference is a sentence in its own right. That is why it is “Section 8”, not “s 8”.

A case
At [42].
A page in a book
At 55.
Legislation
Section 59.

When the reader needs telling: above n

Where the source is not obvious, name it and point back to the footnote that gave it in full. The form is the identifying part of the citation, then “above n”, then the number of that earlier footnote.

For a case, the identifying part is the case name. For a book or an article it is the author’s last name. For an institutional author it is the institution.

Pincite writes “above n __” until you tell it the first footnote number. Fill that in and it fills in the number.

Identifier, above n footnote number, at pinpoint.

A case
Zaoui v Attorney-General (No 2), above n 4, at [42].
A book
Spiller, above n __, at 55.
An institution
Waitangi Tribunal, above n 8, at 51.

Legislation shortens differently

A later reference to an Act drops the year and any jurisdiction, keeping the short title and the provision (r 2.3.1(a)(ii)).

First reference
Crimes Act 1961, s 59.
Later reference
Crimes Act, s 59.
Where the source is obvious
Section 59.

Two styles, and the one you want

The Style Guide sets out a general style and a commercial style (r 2.3.1). The commercial style, used by the legal publishers, repeats the full citation for cases and legislation every time and does not use reference tags.

Everything in this guide is the general style, which is what students, academics, the courts and submissions use. Pincite produces the general style.

Last reviewed 6 August 2026