How to treat supplementary reasons (or Addenda)?
Among courts in several Canadian jurisdictions, issuing an addendum, also called supplementary reasons, is frequent. These reasons pertain to questions that were not addressed in the decision on the merits of the case, such as for, instance, the costs. This type of document is considered a new judgment, and it is assigned a new neutral citation. It is possible to establish a link between the judgment on the merits and the supplementary reasons by adding an additional data element in the heading of the addendum (see 83 of the Guide). For example, an addendum might contain the phrase See also: 2003 ONSC 34, where See also: is a standard label and 2003 ONSC 34 is the core of citation for the main judgment.
