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Bouvier's Law Dictionary, Revised 6th Edition (1856)

FIGURES, Numerals. They are either Roman, made with letters of the Alphabet,
for example, MIDCCLXXVI; or they are Arabic, as follows, 1776.
2. Roman figures may be used in contracts and law proceedings, and they
will be held valid; but Arabic figures, probably owing to the case with
which they may be counterfeited, or. altered, have been holden not to be
sufficient to express the sum due on a contract; but, it seems, that if the
amount payable and due on a promissory note be expressed in figures or
ciphers, it will be valid. Story on Bills, Sec. 42, note; Story, Prom.
Notes, Sec. 21. Indictments have been set aside because the day or year was
expressed in figures. 13 Vin Ab. 210; 1 Ch. Rep. 319; S. C. 18 Eng. Com. Law
Rep. 95.
3. Bills of exchange, promissory notes, cheeks and agreements of every
description, are usually dated with Arabic figures; it is, however, better
to date deeds and other formal instruments, by writing the words at length.
Vide l Ch. Cr. L. 176; 1 Verm. R. 336; 5 Toull. n. 336; 4 Yeates, R. 278; 2
John. R. 233; 1 How. Mis. 256; 6 Blackf., 533.

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