Darwall v Dartmoor NPA (9): How To End Your Speech

The parts of your Advocacy over which you most have (and wish) control are the beginning and end. You will need both a plan and some flexibility in the middle - but you should know both how you intend to start and also how you want to end. (Indeed in Trial Advocacy standard advice is - start with where you want to end) Your Opening has a formula - especially if you are Senior Appellant. There is a bit more flexibility about Endings, but not about their objectives:-

1. Make Clear (again) to the Court what you want
2. Make Clear (again) the main reasons why you should get it
3. Invite the Court to put to you any final queries/ questions/ objections
4. Make Clear that you have finished

The last of those means much more than just sitting down!

Items 1 and 2 will be a summary of your main points - perhaps repeated from your Opening, probably adapted somewhat to fit better the Court's concerns.

Item 3 is critical - however much of a hurry you are in, you have not finished until the Court gives permission. A common formula is:-

• Unless I can be of further assistance to the Court ... ?

Then remain standing while you await the reply - probably a few questions. Vary that wording each time you need to check, until a final 'Thankyou, Mr Heald,' when you say:-

• May it please the Court, those are my submissions.

Then, having done Item 4, you sit down to signal you have truly finished. (Of course, if the Court remembers something, you leap to your feet again)