Here are the examples where zero articles are used:

This is a tenant’s notice which does not have to be in statutory prescribed form but there is an example of how such a notice could be worded at…. The s.26 request has to be in statutory prescribed form, an example of which is given at … The s.25 notice has to be in statutory prescribed form. An example of a hostile notice is given at…

Below are sentences, where ‘a’ is used:

The s.26 request must be in a prescribed form. The tenant’s proposed terms for the new lease must either be attached to or inserted in the schedule to the s.26 request. Both a ‘hostile’ and a ‘friendly’ s.25 notice must be in a prescribed form and pre-printed versions are available for use. If prescribed information is omitted, the s.25 notice may be held to be invalid.

To be honest, in the first group of the examples, I would used the indefinite article before 'statutory prescribed form'. I cannot understand why this expression is used with zero article, while the words 'in a prescribed form' use the indefinite article.

Would you please explain the reason for using zero article and indefinite article in the examples and whether meaning is different?


  • Are either of these examples from a legal document? Legal documents are notorious for not using articles. Legal grammar is very different from what someone might call "everyday run-of-the-mill English grammar."
    – JBH
    Commented Apr 3, 2019 at 7:55
  • Form can be used in different senses. In a form... refers to a single item. In this form.... can be understood to mean in this manner. If you interpret your example in the second sense, no article is required. You are simply replacing this with statutory prescribed Commented Apr 3, 2019 at 8:42
  • These are not from a legal document, but from a textbook for law students. Commented Apr 3, 2019 at 8:51

1 Answer 1


I think what you're seeing is a legal text which is using a legal style of speech where zero articles are common. But most people, even lawyers, have no idea that there is such a thing as a zero article, and as a result they are not consistent with using it or the standard indefinite article.

That said, I do think you are looking at too different uses of "form". One is the talking about the "prescribed manner" in which notices should be given (eg form of words). The other is talking about a printed "form" that someone has to fill in. You can't use zero articles with that sort of noun.

complete in statutory form.

complete the statutory form.

These two commands mean very different things.

  • Hmm... All the quoted sentences in the question seem to use the word "form" in the second meaning you refer to.that is, a template, not a manner. Commented Jan 12, 2020 at 16:38
  • Re-reading, I partly agree with you. They all have the same meaning, but it's the first that is being indicated: "in [a] statutory prescribed manner/way". They've simply been inconsistent about including/excluding the article. To say "in statutory prescribed template" would be an error I don't believe the author would have made. The distinction in meaning is very slight between an abstract legal form (zero article works) and a concrete legal form (zero article does not work) in this context, but I do believe it's there.
    – fred2
    Commented Jan 30, 2020 at 2:53

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