I've been struggling with the definite article and its usage in contracts' names. Please comment and explain, I would appreciate any help!

P.S. Language of origin is Russian.

Examples of the sentences:

  1. Conclusion of additional agreements to (the?) Agreement for financial lease #12345.
  2. <...> attaching a draft of (the/an?) additional agreement #1 to (the?) Suretyship agreement #54321.

One more question: if a name (of a contract or agreement) doesn't contain numbers, do I need to use any articles?

Many thanks in advance!

2 Answers 2


This reads like a legal document to me, but I'm not familiar with Russian grammar.

From L.C. Oates' The Legal Writing Handbook, §25.3.5:

Occasionally, one sees legal writing that has the sound of a police report.

Defendant denies that she hit victim.

This rather terse style is achieved by omitting the article "the." The reason for omitting "unnecessary" articles in police reports may be that information needs to be recorded on forms. Happily, lawyers do not have such requirements, so they do not have to sacrifice a fluid writing style.

The defendant denies that she hit the victim.

Your first sentence reads like a document title. In it, "Agreement" is capitalized, which indicates that "Agreement for financial lease #12345," as a whole, functions as a proper name, eliminating the need for an article (i.e. zero determiner).

In Oates' first example, the common nouns 'defendant' and 'victim' are functioning as proper nouns within the context of the document.

In your examples, all of the agreements are named (though not consistently capitalized), and so I'd say they function as proper names. "Conclusion of additional agreements" in the first sentence is an exception, but I don't think you're looking for an explanation of how titles and verbless clauses function.

Regardless of whether the title of an agreement/contract contains a number, if it is named, you do not need to introduce articles.

This is slightly shaky ground for me, and I'm not sure if I've answered your question, so please let me know.

  • Yes, you absolutely did answer my question, thank you a lot! It was very helpful! Sep 11, 2019 at 10:59

The general rule is: With singular nouns, do not use an article with proper nouns, that is, names. Otherwise you should use either an article, the word "one", or a possessive like "my" or "her". (I wouldn't swear that there are no other words that can take the place of an article, but those are the main ones.)

So normally, you would write, for example, "I am attaching an additional draft of the agreement." Note the "the" before "agreement". But you wouldn't write, "It was signed by the Fred Smith", just "by Fred Smith", because Fred Smith is a proper noun.

We often recognize proper nouns because they begin with a capital letter. But legal documents often capitalize words that have been given special meaning in the document. Like early on their will be a section of definitions, and it will say something like, "You means the policy holder." Then throughout the document they'll capitalize "You" to remind the reader of this special definition. This does not make the word a proper noun in a grammatical sense.

That said, the examples you give are not complete sentences, so it is meaningless to try to apply normal grammar rules. They sound more like titles or items from a bullet list. In such titles or labels, it's common to leave out words that are not necessary to make the meaning clear for brevity. For example, if someone writes an article about, say, a parade to be held on Thursday, they might give it a title of "Parade Thursday". This leaves out the article that belongs in front of "parade" and has no verb. Presumably it's sure for "There will be a parade on Thursday" or something like that.

That appears to be what is happening here. "Conclusion of additional agreements to Agreement for financial lease #12345" is short for something like, "We concluded additional agreements to the Agreement for the financial lease numbered #12345."

  • Thank you for your comment and such a detailed explanation! Sep 11, 2019 at 11:01

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