# Paragraph numbering

Instead of paginating judgments, courts globally have now adopted the practice of assigning paragraph numbers to distinct paragraphs within the text of a judicial opinion.

## Example from the Supreme Court of Namibia

STRYDOM. A.J.A.:

\[1] This is an appeal from the Special Tax Court of Appeal. The respondent ( i.e. the appellant in the Court a quo), objected to a tax assessment by the Receiver of Revenue in terms whereof it was assessed at a rate of 55% of the money recouped in respect of the sale of five of its vessels after they had ceased rendering services in connection with the mining for diamonds to Namdeb Diamond Mining Corporation (Pty) Ltd (“Namdeb”). The respondent maintained that the taxable income, derived from the sale of the vessels, was subject to tax at a rate of 35%. 

\[2] The respondent’s objection was disallowed by the Commissioner for Inland Revenue. The respondent then launched an appeal to the Special Tax Court where it was successful and where that Court ordered that the assessment of that income be reduced in accordance with the rate of normal tax of 35%.

\[3] The appellant (i.e. the respondent, in the Court a quo) was not satisfied with the outcome of the matter in the Special Tax Court and thereupon appealed to this Court. According to sec. 76(9) of the Income Tax Act, Act 24 of 1981 (as amended), an appeal lies directly to this Court.

[*Commissioner of Inland Revenue v Namsov Fishing Enterprises (Pty) Ltd (SA 18/2007) \[2008\] NASC 6 (25 June 2008)*](https://namiblii.org/akn/na/judgment/nasc/2008/6/eng@2008-06-25) 

Numbering paragraphs within electronic judgments effectively solves the problem of pinpoint referencing in electronic judgments. There may be a few details to be considered in terms of deciding what constitutes a paragraph and how is a paragraph indicated, but in general those will be addressed at a court level. 

<mark style="color:red;">**The LII does not add paragraphs to judgments.**</mark>

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