Olowu, Dejo --- "Citing The Law: The Challenges Of Uniform Referencing Style For Internet-Based Resources In The South Pacific" [2005] CompLRes 17 (18 November 2005)

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Citing the Law: The Challenges of Uniform Referencing Style for Internet-Based Resources in the South Pacific

’Dejo Olowu[∗]

The citation of authority in judicial opinions, briefs, articles, texts, annotations, encyclopaedias, and other forms of legal writing is often an unreflective process carried out without conviction or understanding about the purpose of citation, the nature of authority or the function of precedent. Presumably a citation means something to the person citing, and presumably he anticipates that it will have some meaning to a reader.[1]

INTRODUCTION

It is beyond polemics that huge technological advances have taken place over the last two decades. One particular area where this is evident relates to electronic communication otherwise known as “the internet.” A product of the increasing phenomenon of globalisation, the internet came into widespread use in the early 1990s. By using the internet, a person simply sitting in front of a computer can gain access to information that would amount to high volumes of library materials. As would be expected, numerous individuals and business interests have caught up on these advances, translating them into huge economic gains in diverse sectors of the global economy.[2] It is however not the economic dimensions of this new age phenomenon that is the focus of this article, rather, it is the huge impact that technological advances, particularly in the information sector, have wrought upon legal research, whether for academic or other professional purposes related to law.

It is a long-standing tradition in the discipline of law that whether for argumentative or research purposes, lawyers, judges, and scholars of law are required to clearly cite the basis of their reasoning, arguments and opinions. Although the sources of materials for legal research were generally to be found in treaties, statutes, law reports, books, journals, or other printed or hard-surface bound or loose-leaf materials, how to cite legal sources had for long been an endeavour to be mastered. In an age when the process of increased globalisation has introduced tremendous diffusion into the means of locating legal and non-legal resources through dynamic technological alternatives, the absolute reliance on printed or hard-surface materials is fast diminishing in significance. The influence of technological advances in the area of information looms so large that today, both within the South Pacific region and beyond it, the significance of electronic resources in general, and electronic law publishing in particular, is no longer in dispute. Ranging from the speeches of jurists, judicial decisions, law journals, and statutes, the study and practice of law in the broader Pacific region has witnessed, and continues to witness, the tremendous impact of technological revolution.[3]

However, despite the growing acceptance of internet-based resources as another veritable source of law and for legal research, one issue that has remained largely unresolved is how resources found on the internet should be cited.[4]

Against the backdrop of the emergent influence of internet-based resources, therefore, this paper contends that the cacophony in the rules governing the citation of new-fangled species of legal resources calls for serious intellectual deliberation, not the least in the broader Pacific region. This paper examines a range of approaches adopted in some jurisdictions towards the unification of divergent citation methods and rules, and evaluates their significance or relevance in defining citation rules for broader territorial application, in particular, the South Pacific region. Acknowledging this subject to be a relatively novel terrain in legal scholarship, this paper represents a modest attempt at identifying viable trajectories towards the aggregation of the rules of citing internet-based resources in the South Pacific region. While the primary focus of the paper will be the South Pacific region, it may nevertheless hold some implications for other developing states of the world.

WHAT IS THE FUSS ABOUT CITATION?

In defining “citation”, Robert Watt says it refers to “how...law, contained in the report of a case, section of an Act or in a clause of a Regulation, is referred to by the legal practitioner.”[5] Another scholar says “A citation represents all the elements of a case: the facts, the issues and holdings.”[6] With regard to publications based on hard paper materials, those definitions would pose no problem since the requirements for the test of certainty – author, title, place of publication, year, page number are usually rendered in generally identifiable ways. Problems often arise, however, when one attempts to apply the same rules of citing hard-print materials to internet-based resources which may often not have the luxury of those details as are applicable to hard-print publications.[7] The examination of the role of citation at this forum is neither abstract nor esoteric, but a genuine concern. This paper considers that, in the absence of harmonised standards, the entire purpose of citation may be lost altogether on legal practice and research against the backdrop of the increasing popularity and usage of internet-based resources.

What then is the essence of citations in the discipline and profession of law? Nemes and Coss succinctly defined the aim of citation as “to provide a quick method of acknowledging an authority, and to arm the reader with sufficient information to facilitate ready access to authority.”[8] Extrapolating from their modest definition, this paper posits that an accurate citation should fulfil these three cardinal requirements:

(a)	it should clearly identify the document or part of the document referred to with precision;
(b)	it should facilitate direction in locating the document in unambiguous terms; and
(c)	should provide information about the currency of the document or information referred to.

While there appears to be a growing unanimity on the prerogative of every editor or editorial board to formulate their in-house policy on how references in hard-print materials should be cited, there remains sharp divergence on the appropriate form or forms of citing internet-based resources. How then should the legal industry and the legal academe in the South Pacific region address the quest for uniformity of purpose in this regard? Within the framework of existing citation rules for internet-based materials, are there best practices for adoption? These are the questions that form the pivot on which the wheels of this discourse rotate.

CITATION OF INTERNET-BASED RESOURCES IN CONTEXT

In their 597-page seminal work titled Finding the Law, published in 1989, Professors Cohen, Berring, and Olson, did not mention the word ‘internet’ once.[9] Similarly, up to its fifteenth edition, published in 1991, the famous Bluebook contained no rules on internet-based resources.[10] This lacuna was filled in the sixteenth edition published in 1996.[11] Closer home, as recently as 2001, in his extensive discussion of secondary legal authorities and methods in New Zealand, Dr. Russell Smyth did not refer to internet-based resources howsoever.[12] Furthermore, in most of the contemporary works on legal research, few of them address the challenge of appropriate citation of internet-based resources.[13] Broadly speaking, therefore, the law’s engagement with the internet is an incipient experience.

A scrutiny of many of the law journals and other periodicals circulating within the South Pacific region would reveal the discordant rules governing the citation of internet-based resources. While some have detailed guidance on how these resources should be cited, others do not disclose any rule on the citation style of internet-based resources.[14] Approaches to citation have therefore been as varied as what suits the perceptions of publishers and editors. Inasmuch as this paper acknowledges that there are numerous guides and rules on the citation of internet-based resources, this paper simply considers some particularly pertinent rules and standards on this emergent subject.[15]

STANDARDISATION AND CRITICISMS OF PREVAILING CITATION RULES IN THE SOUTH PACIFIC

Since the advent of the age of the internet, various attempts have been made to provide standards and rules to guide the citation of materials that are found via the web. Today, the list of manuals and guides on how to cite internet-based resources are still proliferating and might continue to do so for a very long time to come. Achieving uniformity of rules can indeed be one horrendous task in simple municipal matters, not to mention stylistic matters that relate to millions of web pages! Indeed, in the foreseeable future, what might be readily achievable are sector-specific ‘rules’ – tailored to meet particular professional needs. Notwithstanding the challenge of unification, however, it will always be desirable to establish basic citation rules if only to ensure elegance, coherence, and some degree of uniformity in presentation.

Against the foregoing background, therefore, this paper here assesses some of the more formalised citation rules that particularly portend implications for the South Pacific.

In the Preface to the Australian Guide to Legal Citation (hereinafter the Guide), published by the Melbourne University Law Review in 1998,[16] the mission of the Guide was “to set down and clarify citation customs where they exist, and to determine the best practice where no particular custom has been established.”[17] Although produced as “a uniform system of citation suitable for Australia”,[18] the Guide has no doubt impacted citation rules beyond its original intendment. A direct pointer to this fact is the standardised rule of citation found in the Journal of South Pacific Law, which by and large is the foremost law journal in the South Pacific region. The rule is predicated on instructions in the Guide.[19] It has therefore become germane that any thorough scrutiny of this subject within the South Pacific context should begin with the Guide.

Flowing from the foregoing, there are certain high points in the Guide. For one, its pinpointing style (which enables the reader to ascertain the exact paragraph referred to) is a tremendous improvement over many other international citation guides.[20] The Guide also improves on the Bluebook with its introduction of angled brackets for all URL citations. The absence of angled brackets in the Bluebook makes it difficult to identify the end of the URL cited.

Nevertheless, there are some rules in the Guide that a curious observer would find to be intriguing. With regard to the citation of judicial decisions, scholarly articles, and newspaper articles published on the world-wide-web (internet), the Guide adopted different styles of citing each of these. For instance, for judicial decisions published only in electronic format, the Guide sets one of its rules of citation in the following order:

Name of case (Unreported, Court, Judge(s), Date of Judgment) <Uniform Resource Locater> at Date file retrieved (Copy on file with author), pinpoint (i.e. paragraph in reference).[21]

The Guide renders the example resulting from that format as “Smith v Jones (Unreported, Supreme Court of Victoria, Nathan J, 18 March 1994) <http://www.law.gov.au/smith.html> at 21 March 1994 (Copy on file with author).”[22]

For articles that are published only on the internet, the Guide stipulates the following rule:

Author(s), ‘Title’ (Year) Volume (Issue) Journal Title article reference <Journal Uniform Resource Locator> [paragraph pinpoint].[23]

The example resulting from the above according to the Guide is “Ben White, ‘Racial Vilification and the Freedom of Speech’ (1997) National Law Review 3 <http://www.nlr.com.au> [4].”[24]

In respect of newspaper articles that are published on the internet, where the printed edition cannot be cited, the Guide prescribes the following rule:

Author(s), ‘Title’, Newspaper (City of Publication, Country of publication if overseas), Full date, Newspaper Uniform Resource Locator.[25]

The Guide’s illustration is: “Brook Turner, ‘Higher Education: The Cutting Wedge’, The Australian Financial Review (Sydney), 5 January 1998, <http://www.afr.com.au> .”[26]

The above renditions from the Guide only show how complications could result from even the most painstaking of published rules of internet citation.

While at first sight there would appear to be nothing problematic about the style adopted in the Guide, as rendered above, I consider it unhelpful that the Guide adopted a style of variegated standardisation. What makes it impossible to have a unified rule of citation for materials found on the web, the possibilities of change or removal notwithstanding? My argument here might seem complicated but it is not.

As earlier pointed out, an appropriate citation style should meet the tripartite requirements of identification, direction, and currency. It is my contention that the purpose of identification of the document referred to is fulfilled when one single click of the cursor leads the reader to the very location of the document or where it was last found. To this end, rather than simply citing to the Uniform Resource Locator, it is the position of this paper that citation should be to the exact document.

On another point, since there is a virtually universal recognition of the transient nature of internet-based materials, should all documents found on the internet not be cited by the date closest to their time of being read – which invariably would be last date that the author viewed such documents? The Guide creates a rule for the inclusion of dates of retrieval only in respect of judicial decisions but not for internet-based articles or newspaper items.

This paper argues that, for purposes of veracity, an author should state the date he last viewed or accessed the document he has relied upon or cited. This date should form part of a full citation.

Related to this is the absence of a clear indication of what a date represents where the Guide demands that such be inserted in parentheses. Merely putting date, month and year in bracket after a URL may not communicate any meaningful message to the budding law student or budding computer-literate lawyer. I contend that adding a short statement about the significance of the date in parentheses will do no harm.

The critical nature of this paper must not be seen as a blatant condemnation of the Guide. By no means! All that the paper seeks to do here is highlight some of the notable deficiencies in the rules proffered by the Guide to facilitate how attempts towards standardisation of citation rules in the South Pacific should be conceived in the future. After all, no published style guide has achieved uniform acceptance anywhere, and none may ever do.[27]

Where, then, do we go from here?

PROPOSAL FOR AN INTEGRATIVE CITATION STYLE IN THE SOUTH PACIFIC

There is no gainsaying the fact that jurists and law professionals in the South Pacific states will continue to find electronic resources to be increasingly important to their work. A host of scholars have proffered robust arguments why reliance on electronic resources for research purposes is an idea that has come to stay.[28]

For the smaller states of the South Pacific, an embrace of internet-based resources for legal research purposes is inevitable if only for economic reasons. Illustrative in this regard is the conversion of both the Journal of South Pacific Law and the South Pacific Law Bulletin from hard-print volumes into electronic publications. For lawyers and judges in these states, the huge databases available through the WebPages of the Pacific Islands Legal Information Institute (PacLII) are economical, easily accessible, and constantly updated resources that cannot be ignored.[29] These resources are fast becoming indispensable tools in the administration of justice in the South Pacific region.[30]

It is however very important that if internet-based resources would meaningfully contribute to legal research and the administration of justice in the South Pacific, there must be properly conceived standardisation of those rules that would secure their continued relevance and usefulness. The three cardinal purposes of citation that I have earlier enumerated should be pivotal in arriving at such standards in the future. In formulating the rules for the citation of internet-based resources, therefore, this paper recommends that whatever rule is adopted on the citation of these resources should reflect the identity of the internet-based document with exactitude; should facilitate unambiguous direction to its source; and should establish its currency as at the date of last referencing.

Whatever category the internet-based material may fall into – WWW, FTP, Telnet, or Gopher – the requirement for a complete URL citation must not be sidetracked. Again, learning from the innovative ‘pin-point’ style of the Australian Guide, future citation rules in the South Pacific should adopt a similar indicator. It will only reinforce the requirement of precision.

To that end, while there could be variants to the approach canvassed in this paper, what must remain a constant rule at all times is the need to cite the hard-print location of a document or document part that is also available on the internet where such is available, and vice-versa. Where there is such a parallel reference, a distinguishing statement (e.g. “available at”) should be inserted in the reference.

In essence, the approach in this paper to the challenges of appropriate citation rules on internet-based resources basically represents an amalgam of the 17th edition of The Bluebook: A Uniform System of Citation (for its expressiveness)[31] and the Guide (for its distinguishing features of pinpointing and angled parentheses).

It is apt to demonstrate the approach canvassed in this paper at this juncture.

I.	Document in published in hard-print but also available via the internet

Rule: Furnish reference according to applicable conventional rules on hard-print materials, and then add –

(a)	a comma;
(b)	the words “available at”;
(c)	exact web location, in full, in angled brackets <>;
(d)	the words “last visited” in parentheses along with the very last date that an author had access to that document through that comprehensive location reference;
(e)	pinpoint in square brackets [].

Illustration: Section 2, Labour (Work Permits) Amendment Act 2004, Act No. 9, 2004, available at <http://www.paclii.org/vu/legis/num_act/lpaa2004320/> (last visited 17 October 2005) [2].

II. Document only available in web format (no hard copy or details of hard copy not known)

Rule: Furnish comprehensive internet reference as follows:

(a)	name(s) of author(s), followed by a comma;
(b)	title of the document as found on the internet, italicised, and followed by a comma;
(c)	date of the document (this may be the date it was written, or uploaded, or last modified) – cite the most current, followed by a comma;
(d)	title of parent periodical, or series, or provider of the document (whichever is available, followed by a comma;
(e)	the word “at”;
(f)	exact web location, in full, in angled brackets <>;
(g)	the words “last visited” in parentheses along with the very last date that an author had access to that document through that comprehensive location reference
(h)	pinpoint in square brackets [].

Illustration: Robert Courts, The Real Problem with the Law relating to the Use of Force is not establishing what the Rules of International Law are, but Ensuring that they are Observed. Do you agree?, 2000, at

<http://www.courts.fsnet.co.uk/intllawessay.htm> (last visited 15 Oct. 2005) [8].

My proposal regarding the use of the word “visited” in both cases is, my opinion, syntactically more appropriate since those pages where documents are found on the internet are in fact ‘sites’ that are practically ‘visited’.

The benefits of the style suggested above are unmistakable. Apart from making the sources of citations more ascertainable and easily verifiable, it makes them more meaningful and comprehensible, and more than that, it introduces distinguishing features that would define the beginnings and endings of the web locations of addresses.

CONCLUSION

It will meet the mission of this paper to conclude with the statement by Carol Miller, that: “Legal researchers should not be technophobes, afraid to use technology, nor should we be technophorics, who think that modern technology has all the answers all the time. Electronic databases, including the Internet, should be used in balance with other media to create or continue a sophisticated and informed practice.”[32]

All that has been written in this paper presupposes that lawyers, jurists, legal researchers, and all others who are involved in the legal research or utilise research methods in their work are disposed to respond to the challenges of the advances that have been recorded in the field of information technology over the last couple of years. In meeting those challenges, however, this paper has accentuated the need for the harmonious standardisation of the style of referencing diverse materials found on the internet. While the suggestions here are not out-rightly disconnected from the rules governing hard-print materials in general, this paper has highlighted the critical additional requirements for qualitative citation of internet-based resources.

Of course, much has been written on the theme of electronic resources and their implications for legal research in various parts of the developed world, but the subject remains largely unexplored and under-theorised in the South Pacific. All stakeholders in this region cannot afford to continue to shy away from this subject and must embrace its challenges with the seriousness it deserves. The effort mustered here is a stimulant towards such responses.

Far from being an ex cathedra pronouncement on all the dynamics that would inform the attainment of plausible and concise citation rules for internet-based resources in the South Pacific region, this paper is a modest attempt at stimulating intellectual discourses in this regard and would have achieved its purpose if it engenders further scholarly enquiry.

END-NOTES

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[∗] LL.B (Hons.), LL.M, Obafemi Awolowo University, Ile-Ife, Nigeria; LL.M Human Rights & Democratisation, University of Pretoria, Pretoria, South Africa; PG Dip. International Human Rights, Åbo Akademi University, Turku, Finland; JSD Cum Laude, University of Notre Dame, Notre Dame, Indiana, USA; Barrister and Solicitor (Nigeria); Lecturer, University of the South Pacific School of Law, Port Vila, Vanuatu. E-mail: [e-mail]. Except where otherwise stated, all references to the “South Pacific” denotes the sixteen independent and self-governing states in the Pacific Ocean region that make up the “Pacific Islands Forum”, excluding Australia and New Zealand. See, “Australian Government, Department of Foreign Affairs and Trade”, at

<http://www.dfat.gov.au/geo/spacific/regional_orgs/spf.html> (last visited 17 October 2005). The territories covered are, therefore, those of the Cook Islands, Federated States of Micronesia, Fiji, Kiribati, Republic of the Marshall Islands, Nauru, Niue, Palau, Papua New Guinea, Samoa, Solomon Islands, Tonga, Tuvalu, and Vanuatu

[1] Merryman, J., 1954, ‘The Authority of Authority’, Stanford Law Review, 6 Stan. L. Rev. 613, quoted in Nemes, Irene & Coss, Graeme, Effective Legal Research 2nd ed. (Chatswood: Butterworths, 2001) 19.

[2] The multidimensional ramifications of the globalisation phenomenon have enjoyed tremendous scholarly engagement and should not becloud the focus of this paper. For pertinent readings and divergent views on the technological and economic gains of globalisation, see International Labour Resource and Information Group (ILRIG), An Alternative to Globalisation (Cape Town: ILRIG, ILRIG Globalisation Series No. 1, 1998); Stiglitz, Joseph, 2000, Globalisation and Its Discontent; The World Bank, Globalisation, Growth, and Poverty (Washington, DC: World Bank and Oxford University Press, 2002); and Honey, Rex, 2002, ‘The Impact on Human Rights: An Introduction to the Symposium: Interrogating Globalisation’, Transnational Law & Contemporary Problems, 12 Transnat’l L. & Contemp. Probs. 1-12.

[3] See generally Archie Zariski, ‘“Never Ending, Still Beginning” – A Defence of Electronic Law Journals from the Perspective of E Law Experience’, Computerisation of Law Resources, at

<http://www.worldlii.org/au/other/CompLRes/1997/19/index.html> (last visited 17 October 2005). At the present time in the pacific region, there is a growing number in scholarly law journals that are published exclusively online. Examples include Journal of South Pacific Law, South Pacific Law Bulletin, Murdoch University Electronic Journal of Law, etc.

[4] See generally Rozenberg, Pearl, 1999, ‘Referencing and Citation of Internet Resources – “the truth is out there”’, Computerisation of Law Resources, at

<http://www.austlii.edu.au/au/other/CompLRes/1999/41/index.html> (last visited 17 October 2005).

[5] Watt, Robert, Concise Legal Research, 5th ed (Sydney: The federation Press, 2004), 2.

[6] Johns, Francis, ‘Citator Wars – Tracing the Golden Web Online: The US Experience’, Computerisation of Law Resources, at

<http://www.worldlii.org/au/other/CompLRes/1999/25/index.html> (last visited 17 October 2005) [21].

[7] Rozenburg, Pearl, ‘Developing a Standard for Legal Citation of Electronic Information’, Computerisation of Law Resources, at

<http://www.worldlii.org/au/other/CompLRes/1997/14/index.html> (last visited 17 October 2005) [2].

[8] Nemes, Irene & Coss, Graeme, Effective Legal Research 2nd ed. (Chatswood: Butterworths, 2001) 20.

[9] Cohen, Morris L., Berring, Robert C., & Olson, Kent C., Finding the Law (St. Paul: West Publishing, 1989). The work also did not mention the word “electronic”.

[10] Columbia Law Review Assn. et al. eds., The Bluebook: A Uniform System of Citation, 15th ed., (Cambridge, MA: Harvard Law Review Association, 1991).

[11] See, Columbia Law Review Assn. et al. eds., The Bluebook: A Uniform System of Citation, 16th ed., (Cambridge, MA: Harvard Law Review Association, 1996) 124.

[12] See Smyth, Russell, ‘Judicial Robes or Academic Gowns? – Citation of Secondary Authority and Legal Method in the New Zealand Court of Appeal’ in Rick Bigwood, ed., Legal Method in New Zealand: Essays and Commentaries (Wellington: Butterworths, 2001) 101-130.

[13] See, for example, Robert Watt’s Concise Legal Research, 5th ed (Sydney: The federation Press, 2004), 7, which even though it mentions “electronic citation”, does not reflect the difficulty in conceptualizing how electronic resources should be cited. See also Holland, James, A., et al, Learning Legal Rules, 5th ed. (Oxford: Oxford University Press, 2003), pp. 50-53, which discussed extensively the significance of internet-based resources for legal research but avoided the discordant tunes on how to cite them.

[14] See, for example, The Journal of Pacific Studies, which contains nothing in its “Information for Contributors” as at the time of publishing its latest edition.

[15] In this regard, this paper evaluates the Australian Guide to Legal Citation published by the Melbourne University Law Review Association, 1998; The Bluebook: A Uniform System of Citation, 17th edition, published by the Columbia Law Review Association, et al, eds., 2000; the American Psychological Association (APA) Guidelines, developed by Russ Dewey, at <http://www.psychwww.com/> (last visited 17 October 2005); the MLA Guidelines, developed by Janice R. Walker, at

<http://www.columbia.edu/cu/cup/cgos/idx_basic.html> (last visited 17 October 2005); the Turabian’s Reference-List Style, developed by Maurice Crouse, at <http://www.people.memphis.edu/~mcrouse/elcite.html> (last visited 17 October 2005); the Adventures of Cyberbee, developed by Linda C. Joseph, at

<http://www.cyberbee.com/citing.html> (last visited 17 October 2005); the Murdoch University Electronic Journal of Law Submission Guidelines, at

<https://elaw.murdoch.edu.au/index.php/13218247/about/submissions#authorGuidelines> (last visited 17 October 2005); and the Journal of South Pacific Law, Guidelines for Submissions, at

<http://law.vanuatu.usp.ac.fj/jspl/submissions> (last visited 17 October 2005).

[16] Melbourne University Law Review Association Inc., Australian Guide to Legal Citation – Electronic Edition (Melbourne: Melbourne University Law Review Association, 1998) [hereinafter Australian Guide to Legal Citation].

[17] Ibid., ix.

[18] Ibid.

[19] See, for example, “Journal of South Pacific Law, Guidelines for Submissions”, at <http://law.vanuatu.usp.ac.fj/jspl/submissions> (last visited 17 October 2005) (stating that submissions must comply with the “citation policy” of, inter alia, the Australian Guide to Legal Citation – Electronic Edition.

[20] In this regard, I am referring to The Bluebook: A Uniform System of Citation, 17th ed., (Cambridge, MA: Harvard Law Review Association, 1996); the Canadian Guide to Uniform Legal Citation, 5th edition, (Scarborough, ON: Carswell, 2002); the ALWD Citation Manual: A Professional System of Citation, 2nd edition, (Aspen Publishers, 2002).

[21] Australian Guide to Legal Citation, above note 9, at 38.

[22] Ibid., at 39.

[23] Ibid., at 53.

[24] Ibid., at 54.

[25] Ibid., at 65.

[26] Ibid.

[27] See generally, Nemes & Graeme, above note 8, ibid., noting previous unsuccessful attempts at uniformity. See also Rosenberg, above note 4 [11], lamenting that there “is no uniformity at all within any of the [existing] guides. No common standard has appeared and it would appear no chance of one doing so in the future.”

[28] See, e.g., Zariski, above note 3, at [2]; McGregor-Lowndes, Myles & Davidson, Alan, The Internet for Lawyers (North Ryde: The Law Book Company, 1997) v; Blackman, Joshua & Adkins III, Andrew Z., ‘Study Proves Lawyers Leaping Onto the Net’, The Internet Lawyer, Press Release, 27 January 1997

<http://www.internetlawyer.com/Itechpr.htm> (last visited 17 October 2005); Dayal, Surendra, E-Law Research: Your Guide to Electronic Legal Research (Canberra: Butterworths, 2000) xi.

[29] Pacific Islands Legal Information Institute (PacLII), at

<http://www.paclii.org/databases.html> .

[30] See Bob Hughes, ‘Putting the Law of the South Pacific States on the Net’, Computerisation of Law Resources, at

<http://www.worldlii.org/au/other/CompLRes/1999/22/index.html> (last visited 17 October 2005), for an analysis of the impact of these PacLII resources in the South Pacific.

[31] See, Columbia Law Review Assn. et al. eds., The Bluebook: A Uniform System of Citation, 17th ed., (Cambridge, MA: Harvard Law Review Association, 2000) Rule 18.2.1-18-2.6, pp. 132-140.

[32] Miller, Carol, R., 1997, ‘Legal Research on the Internet: A 10-Step Strategy’, Texas Bar Journal 60 Tex. B. J. 1169.