A judicial order is best read in layers. The result may be clear from the final paragraph, but its significance depends on the question the court was asked to decide, the procedural stage at which it was asked and the facts the court treated as material.

The first task is to identify the issue. An observation made while deciding an interim application does not necessarily resolve the merits, and a decision confined to maintainability may say little about the underlying rights. The pleadings, relief sought and earlier procedural history provide the boundaries within which the reasoning operates.

The next task is to separate the governing proposition from observations tied closely to the facts. A case note should record the statutory provision or principle applied, the factual premise on which it was applied and any express qualification in the judgment. This prevents a broad sentence from being detached from the problem it was written to answer.

Relief must then be read with precision. A petition may be allowed only in part; an order may remit a matter without deciding it; or a direction may operate for a limited period. The operative portion should be read together with the reasons, not as a substitute for them.

A useful case note is therefore selective rather than exhaustive. It states the issue, records the holding, explains the route taken by the court and identifies the immediate procedural consequence. Wider implications should be described cautiously and tested against later decisions before they are relied upon.