Medium-Neutral Citations (MNC)

Tausi assigns a Medium-Neutral Citation (MNC) to every decision. The MNC uniquely identifies the decision globally and allows for decisions to cite other decisions with clarity and accuracy.

Components

Tausi considers the MNC to have two different flavours:

  • the core citation, which is sufficient to uniquely identify the case

  • the full citation, including the party names, docket number, core citation and delivery date

While the core citation is sufficient to uniquely identify a case, the full citation is easier to remember and is commonly used when citing a decision.

For example, a full citation is:

Al-Jalal Enterprises Ltd v Gulf African Bank Civil (Civil Case No. 674 of 2014) [2018] KEHC 500 (KLR) (3 August 2018)

and the corresponding core citation is:

[2018] KEHC 500 (KLR)

Core citation

The core citation has four components that uniquely identify this case in KLR’s systems.

[<delivery year>] <court code> <serial number> (KLR)

  • <delivery year> is the year in which the decision was delivered.

  • <serial number> is generated by Tausi and is effectively assigned by KLR. This is necessary because the courts themselves do not (yet) uniquely number their decisions. The serial number starts at 1 for each court, each year.

  • (KLR) is included to indicate that the citation has been assigned by Kenya Law.

Full citation

The full citation is formed by combining the core citation with the parties, docket number and delivery date. The full citation may change if a decision’s party list needs to be updated (to correct a typo, for example).

When is a citation assigned to a decision?

The core citation is assigned on a first-come-first-served basis during the decision data capture workflow, once a decision has been captured, inventoried and reviewed. At this point, the decision has been signed off and is ready to be published. The serial number is calculated (see below) and the citation is stored.

The citation is assigned only at this stage (and not earlier) because it is only after review that the court and year are confirmed. Before this, they may change (and the serial number would then be incorrect).

Once the core MNC has been assigned, it should never change. An editor can force the MNC to be re-generated, but the old serial number will never be re-used.

Internally, the serial number is calculated by finding the maximum assigned serial number for the court code and year, and incrementing it by one.

Akoma Ntoso FRBR URI

The core MNC corresponds directly to the Akoma Ntoso FRBR URI, which is Akoma Ntoso’s mechanism for uniquely identifying a work (decision). You can think of the core citation and the FRBR URI as being different ways to present the same information.

The FRBR URI is used inside the decision’s Akoma Ntoso XML and by the Tausi API.

Tausi generates an FRBR URI that has the format:

/akn/<country>/<doctype>/<actor>/<date>/<number>

where:

  • <country> is the ISO 3166-1 two-letter country code, in this case ke

  • <doctype> is the Akoma Ntoso document type, in this case judgment

  • <actor> is the court code

  • <date> is the delivery year

  • <number> is a unique number for this decision, scoped by the court and year

For example, the core citation:

[2018] KEHC 500 (KLR)

can be expressed as an FRBR URI:

/akn/ke/judgment/kehc/2018/500

The FRBR URI is assigned to a decision at the same time as the core citation.