05/02/2020 Galloway v Frazer & Ors [2016] NIQB 7 (27 January 2016) cogent explanation, from relying on that matter at a later date to justify the order which has been made. The court will be quick to punish material non-disclosure. The judge should then comment expressly on the basis upon which leave, if any, has been granted, and identify the relevant gateways and causes of action. The ex parte order should be drafted for the approval of the judge and he should settle it at the conclusion of the hearing. The order should specify on its face under what gateways and for what causes of action leave to serve out of the jurisdiction has been granted. (v) Skeleton arguments should be as brief as reasonably possible and should never be used to adduce factual evidence. Affidavits are for facts. The judge should be able to find all the facts solely by looking at the affidavits without having to hunt through exhibits, correspondence and skeleton arguments. Affidavits should not be used as an opportunity to rehearse legal argument or make comments. Skeleton arguments are for legal propositions and comments. The parties should pay attention to the Practice Direction. Key authorities must be marked with an asterisk and the relevant sections of any other authorities should be underlined. Producing and relying on numerous authorities can be counterproductive. In most circumstances it should only be necessary to produce one authority for any particular proposition of law. Failure to adhere to these elementary but fundamental rules may result in a judge refusing to hear the application until there has been full and adequate compliance with the Practice Direction. BAILII: Copyright Policy | Disclaimers | Privacy Policy | Feedback | Donate to BAILII URL: http://www.bailii.org/nie/cases/NIHC/QB/2016/7.html file:///Users/nerissa/Downloads/Columbia CSV/Galloway v Frazer & Ors [2016] NIQB 7 (27 January 2016).htm 26/26