skills/appeal-grounds-drafter/SKILL.md

---
name: appeal-grounds-drafter
description: >-
  Draft and review grounds of appeal tied to challenged findings, preserved
  errors, the applicable standard of review, the record, prejudice, and relief.
  Use for civil, commercial, administrative, tribunal, or other appellate matters.
---

# Appeal Grounds Drafter

Draft grounds that identify an appealable error and its consequence. Do not use
an appeal as an unstructured retrial or introduce material outside the record
without a recognised procedural basis.

## Intake

Obtain the jurisdiction, appellate route, challenged judgment or order, decree,
reasons, lower record, pleadings, evidence, transcripts, objections, submissions,
issues, dates of decision and service, limitation position, permission or
certificate requirements, existing stay, client objective, and relief sought.

## Drafting method

1. Verify the appeal lies to the proposed forum, who may appeal, whether leave is
   required, which orders are appealable, and the current filing and service deadline.
2. Build a finding-and-record table: challenged paragraph, finding, issue, party's
   case below, supporting material, contrary material, objection, and preservation.
3. Identify the governing standard for each issue: law, fact, discretion,
   procedure, jurisdiction, mixed question, or constitutional review.
4. Classify the proposed error precisely: wrong test, misconstruction, irrelevant
   consideration, ignored material evidence, no evidence, procedural unfairness,
   inadequate reasons, excess of jurisdiction, perversity, or abuse of discretion.
5. Distinguish an adverse outcome from reversible error. Explain materiality,
   prejudice, and why the result or process may have differed.
6. Address harmless-error, waiver, acquiescence, invited-error, preservation,
   alternative-basis, mootness, and finality objections.
7. Draft one proposition per numbered ground. Cite the challenged finding and
   record locator without pleading evidence or argument at excessive length.
8. Separate grounds requiring permission, new evidence, additional findings,
   remand, rehearing, substitution, variation, costs, or interim stay.
9. Test every ground against the judgment as a whole and against the respondent's
   strongest answer.
10. Reconcile the notice, grounds, prayer, chronology, record citations, and
    proposed order.

## Output

Provide a jurisdiction and deadline note, finding-and-error matrix, draft grounds,
preservation and standard-of-review table, record gaps, relief analysis, and
filing checklist.

## Guardrails

Do not invent preservation, quote the record inaccurately, recast factual
disagreement as legal error, or omit adverse reasoning. Do not assume a notice,
review, revision, intra-court appeal, statutory appeal, or special-leave route is
interchangeable. Require appellate counsel to verify current rules and deadlines.