Journal of Information, Law and Technology

A Defence of Plain HTML for Law: 
AustLII’s Approach to Standards

Philip Chung
Co-authors: Daniel Austin and Andrew Mowbray

Australasian Legal Information Institute (AustLII)
<http://beta.austlii.edu.au/>

philip@bondi.austlii.edu.au

This is a refereed article published on: 29 February 2000 

Citation: Chung P et al, 'A Defence of Plain HTML for Law: AustLII’s Approach to Standards', 2000 (1) The Journal of Information, Law and Technology (JILT). <http://www.law.warwick.ac.uk/jilt/00-1/chung.html>

Abstract
With its public access objective, AustLII is very concerned with accessibility and usability issues. Web technologies such as the use of frames, portable document format (PDF) files, and images are discussed based on AustLII’s notions of accessibility and usability. Some considerations are also made in relation to general web standards as well as legal specific standards.

Keywords: electronic publishing, standards, accessibility, usability

1. Introduction
With the development of various web technologies that claim to allow web sites to become more accessible and usable, it is useful to consider some of them from AustLII’s perspective as a very large web site concerned with content delivery in a non-commercial context. We will consider the issues of accessibility, usability and the practical limitations that face AustLII in determining the type of technologies that should be adopted given the nature of our users. Also, we will be considering the impact of the various technologies and standards that are available in the context of one of AustLII’s main objectives which is to maximise public access to legal information.

2. Accessibility and the Web
As the World Wide Web is used by more and more people, it is not surprising that an increasing number of less technically proficient people will be using it. With this in mind, it is crucial that sites wanting to maximise access to the largest proportion of the people using the Internet consider carefully the implications of adopting various technologies. Of course many sites are principally concerned with targeting specific audiences for commercial gain, and so may have a different perspective.

2.1 What does ‘Web accessibility’ mean?
One definition offered by Chuck Letourneau is as follows:

anyone using any kind of web browsing technology must be able to visit any site and get full and complete understanding of the information as well as having the full and complete ability to interact with the site – if that is necessary (Letourneau; 1998).

This definition should be read in the context of the particular constraints of the environment being considered. One of the key points from the definition above is the notion of ‘full and complete understanding of the information’. Barriers to ‘full and complete understanding’ include:

•	The language barrier: Generally, most web sites are available in only one language and so would exclude many visitors who cannot understand that particular language. Translation software, if available, may provide some hints as to the contents of the page but these are useful only for words in links and not long passages. 

•	The jargon barrier: Even if the site contains materials written in the native-tongue for the user, the concepts used may be so specialised as to alienate many of the users. 

•	The design barrier: This relates to way the web site itself is designed and whether thoughts have been given to how the site is structured and what technologies are adopted.

•	The ‘Somebody else’s problem’ barrier: Some web page editing programs produce code which is not very ‘clean’. The resulting page seems to be fine on the author’s browser but this page may not be accessible on other browsing technologies.

•	The ‘Latest is greatest!’ barrier: The newest languages and applications may require the visitor to have the newest hardware and newest viewers in order for the web pages to function properly. It is important that the information being conveyed is not lost because the user does not have access to a certain type of technology.

•	The ‘I didn’t know that!’ barrier: Given the initiatives of various organisations around the world such as the World Wide Web Consortium (W3C - <http://www.w3.org/>), it is becoming very difficult to suggest that benefits of accessible web site design are not known.

While some barriers are easier to deal with than others, nevertheless, it is important that the general notion of web accessibility be kept in mind during any design process. Many guidelines have been developed that provide tips and suggestions in relation to designing and building accessible web sites.

2.2 Why Accessibility?
There are a number of dimensions when considering the issue of web accessibility and one of these would be whether it is an issue at all. Some discussion follows which briefly outlines some of the reasons for taking the issue of ‘web accessibility’ seriously. One view is to consider web accessibility as assistive technology and should be considered from the perspective of disabilities: visual, auditory, motor and cognitive.

If altruistic reasons are not sufficient, careful consideration should be paid to legal requirements for accessibility. The Australian Human Rights and Equal Opportunity Commission <http://www.hreoc.gov.au/> has suggested that the Disability Discrimination Act 1992 covers materials generated for the publication onto the Internet. There are also other reasons why web accessibility should be considered seriously. One obvious reason is that the more accessible a site is, the more likely that it will be visited. A more pragmatic view is that accessible web sites that adhere to standards are easier to maintain. It is important to realise that the notion of ‘accessibility’ goes beyond designing for users with disabilities or special needs.

2.3 What are AustLII’s constraints? 
While the notions of accessibility and usability are important, it is also important to be aware of the practical constraints that exist in an environment. Some of constraints faced by AustLII include:

•	Types of Users: AustLII users come from a diversity of backgrounds ranging from an individual person wanting to find out what to do in a residential tenancies dispute to a law librarian assisting students in locating a section of an act to legal practitioners wanting to find a recent decision of the High Court of Australia. 

•	Bandwidth available to users: many of our users have equipment or technical constraints. For example, some of them connect to the Internet via a slow modem. Others may be coming through from remote areas in Australia with ‘low end’ equipment.

•	Number of users: with more than 500 concurrent users at peak times and up to 200,000 ‘hits’ per day, AustLII needs to consider the resource implications of maintaining the site and all the documents it holds.

•	Limited resources: due to the limited resources that are available to AustLII, maintainability becomes a very important issue. 

While AustLII does not pretend to have satisfied all accessibility guidelines, we do take them into account when considering the practical design and implementation of the site within the constraints we face. Compromise and trade-offs are necessary.

3. Usability Issues
Accessibility is by definition a category of usability: software or systems that are not accessible to a particular user are not usable by that person (Bergman et al; 1995). However, usability includes other components. It is traditionally associated with the following five usability attributes (Nielsen; 1993, p26):

•	Learnability: the system should be easy to learn so that the user can rapidly start getting some work done with the system. In the context of the Web, browsers have dealt with many aspects of this through the use of standard icons and lexicons. A web site’s consistent navigational aids will also contribute to improving learnability.

•	Efficiency: The system should be efficient to use, so that once the user has learned the system, a high level of productivity is possible.

•	Memorability: The system should be easy to remember, so that the casual user is able to return to this system after some period of not having used it, without having to learn everything all over again. General navigational aids are provided by standard browsers such as Netscape and Internet Explorer.

•	Errors: The system should have a low error rate, so that users make few errors during the use of the system, and so that if they do make errors they can easily recover from them. Further, catastrophic errors must not occur. This may pose a great challenge for systems in general and web sites in particular.

•	Satisfaction: The system should be pleasant to use, so that users are subjectively satisfied when using it; they like it.

However, in the context of web design, it is also important to have ‘discoverability’ – how easy it is to discover and find the type of resources on the site. Further, the nature of the medium requires the site to be ‘reader-friendly’. This is especially the case for a legal web site since the bulk of the material is textual. In the context of the web, usability may be interpreted as ‘how easy it is to find, understand and use the information displayed on a Web site.’(Keevil; 1998, p271.)

3.1 Ten usability heuristics and AustLII
A usable system is one that is ‘accessible, maintainable, visually consistent, comprehensive, accurate, and oriented around the tasks that users intend to perform.’ (Keevil; 1998, p271.) Jakob Nielsen, a usability expert, provided a list of ‘ten usability heuristics’ <http://www.useit.com/papers/heuristic/heuristic_list.html> (as at 22 June 1999) for the evaluation of systems in general. These have been adapted to heuristics for the Web by Keith Instone (Instone; 1997). Let’s briefly examine how AustLII matches up with these heuristics.

3.1.1 Visibility of system status
‘Where am I?’ and ‘Where can I go next?’ are the two most important questions asked by users when they arrived at a particular web page. AustLII has strived to provide users with a sense of where they are at any point in time through its consistent site structure used in URL (Uniform Resource Locator) links. Also, the AustLII logo will allow users to ‘jump’ back to the front page of AustLII in case the user entered AustLII other than from the front page. A transparent structure for URLs provides status information on AustLII. In the new AustLII interface, more status information is provided at the top of a page, for example, in the World Law Index, status information are provided in the form of ‘World Law >> Subject Index >> Privacy’. 

3.1.2 Match between system and the real world
Trying to provide terms and concepts familiar to the user rather than system oriented terms can be a challenge. The diverse user base that AustLII has means that it would be nearly impossible to provide an exact match between the system and the real world. However, while it is clear that not all users coming to our site are lawyers or have a background in law, the provision of our secondary materials and World Law Index  <http://beta.austlii.edu.au/links/World/> does assist in this mapping. AustLII may need to change some of the vocabulary used to address users in the sense that more and more users will be accessing the site from a non-legal background as well as from a non-technical background.

3.1.3 User control and freedom
Given the amount of materials available on AustLII, it is important that users still feel that they are in control at all times. One of the ways of doing this is to provide a consistent ‘look and feel’ to the site. In particular, the AustLII logo will always take a user back to the homepage of AustLII if the need arises. This ensures that at all times, a user is able ‘jump’ back to the beginning to start again. There are also links from within a specific database to return to the homepage of the database.

3.1.4 Consistency and standards
Since the beginning of AustLII, consistency has always been one of the guiding principles for designing the site. This can be seen by the consistent navigational aids used in our databases. AustLII has endeavoured to both adopt standards that will permit the maximum number of potential users to the site as well as actively promoting them to its users and data providers. Only through consistency and standards will the objective of maximising public access to legal information be met. For web accessibility and usability, a site’s approach to standards determines its ‘real’ accessibility since no one site on the Web is an island. From AustLII’s perspective, this is even more so since we would like to create a site that is conducive to be linked by other sites.

3.1.5 Error prevention
It is important that the system assist in the prevention of errors from users. With the amount of information on AustLII as well as the number of features supported by AustLII, first time users may find the task of locating information on the site a bit daunting. We have tried to minimise the number of distractions to users by providing a fairly ‘clean and lean’ site to ensure the maximal amount of attention can be paid to the research task at hand and thus minimise errors. AustLII caters for ‘web searchers’ and not ‘web surfers’.

3.1.6 Recognition rather than recall
Consistency is the key to recognition. By providing a consistent set of navigational aids, users are able to easily recognise the common feature set provided by AustLII. For example, a typical page for a section of an act will have the following elements: ‘Index’, ‘Table’, ‘Search’, ‘Notes’, ‘Noteup’, ‘Previous’, ‘Next’, ‘Download’, ‘Help’. This is demonstrated by the following figure which shows section 7 of the Copyright Act 1968 (Cth) with the standard set of navigational aids for legislation.

Figure 1: Standard set of navigational aids for legislation.

Also, consistency in the naming structure of our links does facilitate the recognition process.

3.1.7 Flexibility and efficiency of use
Features that are flexible enough to cater to both inexperienced and experienced users should be provided. The effective use of hypertext links can provide the necessary flexibility and efficiency. AustLII has made its site very amenable to ‘bookmarking’ through its site structure and the stability of its URLs. Bookmarking allows users to efficiently return to the place in the AustLII site structure that is of interest to them. Also, this provides an efficient way for users to create links to the site which is an important aspect of AustLII’s public access objective.

3.1.8 Aesthetic and minimalist design
It is crucial, given the nature of the information AustLII provides, that the design of the site does not include elements that will be likely to distract or slow down the transfer of information. We have adopted a fairly minimalist approach to the use of graphics and other emerging technologies that place an unduly technical burden on our users. For example, the new AustLII homepage has only one main graphic which is the AustLII logo – can be viewed at: <http://beta.austlii.edu.au/>.

3.1.9 Help users recognise, diagnose, and recover from errors
The new AustLII interface will provide a more detailed response when a user encounters errors. For example, there will be more suggestions when a user has entered a wrong search syntax, for example. It seems that misspelling of search terms is a common problem. Users may not realise that they have misspelt the term and when the system responds with ‘zero results’, the user often assumes that the system has behaved abnormally and seeks points of clarification through AustLII’s feedback facility. One possible approach to minimise this problem is to highlight the words entered in the search that returned no documents and to advise when these are common words. 

3.1.10 Help and documentation
Currently, AustLII makes available a number of guides downloadable from our web site which provide information about how to use its services. There is also a FAQ (Frequently Asked Questions) which provides answers to some commonly asked questions. Also, we provide a feedback facility for users to send in their queries via email concerning any aspects of AustLII and its services. Over the coming months, we will be embarking on a new cycle in the development of new materials and exploring ways to introduce new users to AustLII and its services. We are also investigating innovative approaches to integrate the documentation into our site so that users feel that help is available and nearby if they need it.

4. Technologies Impacting on Accessibility and Usability
The brief discussion above provides some of the bases for considering the impact of a number of web technologies and standards on accessibility and usability in relation to a large legal web site such as AustLII. In particular, we will be focusing on the use of frames, portable document format (PDF), images, and metadata.

4.1 Frames
The development of frames has resulted in many debates as to its relevancy and usability. Its initial implementation failed to impress many web design experts at the time. Many voiced philosophical objections to a frame-based model which was considered to undermine the original model of the ‘page’ which is considered to be a single unit of information brought to the user by a single unit of navigation and is easily retrievable by a single address. Among them was Jacob Nielsen who commented that ‘with frames, the user’s view of information on the screen is now determined by a sequence of navigation actions rather than a single navigation action.’ (Nielsen; 1996b.)

Others have provided more practical reasons for not using frames. There are navigational problems since the address or location refers only to the first level of the frameset and not the individual frames (Muehlbauer; 1998). Rosenfeld and Morville have also pointed out that the use of frames may take up valuable screen space, may affect display speed as well as increasing the complexity of the page design (Rosenfeld et al; 1998, pp 61-62). Further, there is a security vulnerability with using a frame-based model known as ‘frame spoofing’ on some web browsers. This allows a malicious attacker to insert information into a frame within another site’s window. In addition, for printing purposes, the user can only print a frame at a time but not the whole page. 

4.1.1 Accessibility and usability
As frames may crash older browsers and may behave differently on different browsers, the ‘full and complete ability to interact with the site’ may be affected. While more recent implementations of frames have reduced some of the variations in behaviour, nevertheless, this does have considerable accessibility and usability implications. Further, text browsers such as Lynx still have problems when dealing with frames which may be problematic for users that rely on such browsers. Of course, one way to deal with this issue would be to provide a ‘No Frames’ version of the page which is fairly common on many web sites. However, this tends to increase the cost of maintaining the site.

4.1.2 Transparency and consistency
One of the most important issues for AustLII is the ability for other sites to make links to materials on this site. This means that we need to have a consistent and transparent link scheme with which our site is based. With a frame-based model, the URL of the pages within the frame are ‘hidden’ from the user. More effort from the user is required in order to find out the location of the resource such as having to open a new browser window. It is this feature of a frame-based model that prevents AustLII from considering this technology as a possibility to be used for the materials that we wish to make available to the public which includes our primary and secondary materials databases.

4.1.3 When frames might work
A frame-based model might work in a situation when there is a homogeneity in the equipment used. For example, if there was total control over what browser is being used for viewing pages then a frame-based model may be a possibility. However, the diversity of the users served by AustLII means that we have to deal with many different types of browsers. Also, it has been suggested that when bookmarking and linking to specific pages are not critical, then it may be reasonable to adopt a frame-based system (Musciano; 1999). An example of this is a multi-page form where the user will be less inclined to bookmark a page in the middle of filling out a form. 

4.2 Portable Document Format (PDF)
Portable Document Format or PDF files have been heralded as a new cross-platform way of delivering visually rich content via the Internet. It is true that when PDF files are printed, they maintain most of the formatting and layout of the original documents. While this may be useful from a print-medium perspective, there are a number of accessibility and usability problems with this format for web sites in general and legal web sites in particular.

4.2.1 Accessibility
Adobe Systems, the owner of PDF, has acknowledged that ‘For the visually disabled, there are some accessibility issues associated with PDF and the use of Adobe Acrobat viewers for viewing PDF files.’ (Adobe Systems; 1999.) This has resulted in a site that is set up to deal with accessibility issues. The fact that this is done highlights the severity of the problem. Text based browsers will not be able to view this type of file as they require a special plug-in to be installed on the user’s system. In other words, the user needs to install Acrobat Reader and then will also have to install an Acrobat access patch so that PDF files can be converted back to HTML or ASCII text. The quality of the conversion varies fairly dramatically and so the end result may not be useful for a user with special needs even after going through such a lengthy process. This is an example of a tool that may be accessible but potentially be creating inaccessible content <http://trace.wisc.edu/docs/eitaac-l/web/eitaac.9901/msg00049.html> (as at 2 July 1999).

Even for the user with a graphical browser and an appropriate plug in, reading the document on screen is still fairly difficult as the PDF file has been optimised for print. Generally, legal documents are text based and do not have a very complex layout in which case the user is more interested in the content and structure of the document than the presentation layout. It is important that the user knows where each section is but does it really matter if each section begins with a 2cm indent? 
4.2.2 Searchability
As a format for information retrieval and searching purposes, PDF leaves much to be desired. Generally, PDF files present a great difficulty as files to be indexed for searching as they are stored in a proprietary and binary format which can even be stored as image-only PDF. This means that user has to download the whole file before it can be used in any way. The user then will either browse or perform a ‘Find’ to see if the information being sought is in the file. It may be possible to extract the text from a PDF file if it was not stored as image-only PDF. However, the extra tools required and the extra time needed means that the whole process may become fairly inefficient.

4.2.3 Ability to be linked
As AustLII encourages other sites to link to its materials, it is crucial that the location of the materials is transparent and easily obtainable. Further, we are working to allow better ways of linking to materials on AustLII. For example, it is desirable to be able to refer to a specific section of a piece of legislation: s10 of the Copyright Act 1968 (Cth) and be able to link to it directly. This type of pinpoint citation for legislation is achieved by AustLII through dividing an act into individual sections and being able to provide a transparent and consistent URL for linking. However, using PDF alone, this option only allows the user to download the complete Act or case, but does not allow for the convenience of being able to ‘jump’ to a specific section or paragraph. 

4.2.4 Alternative delivery
While we have argued that PDF cannot be the primary delivery medium for our materials due to AustLII’s public access policy, this is not to say that PDF should not be used as an alternative mechanism for access to materials. This is especially the case for sites wanting to make the materials available quickly and/or would wish the materials to look much the same as the print version. Also, it may be necessary to provide material in this format where there is no alternative means of making it available. This is true in the provision of much of the multi-lingual materials on the Web. However, as noted in the arguments put forward above, PDF should not be the only delivery mechanism if accessibility is the main concern.

4.3 Graphics, image maps and animation
4.3.1 Accessibility and usability
AustLII strongly believes that unless an image adds to the meaning of the page, provides an appropriate navigational aid, or provides a suitable context, then it should not be placed on the page. Since the inception of AustLII in 1995, only a small number of images are used on the whole site. These included the AustLII logo and banner; images for ‘new’, ‘announcement’, ‘updated’, and a ‘search’ icon. This minimalist philosophy is carried forward to the new design of AustLII’s web site (see Figure 2 above). The quantity and the size of images affect page level usability in terms of the possible distractions and longer load time that may result. Any unnecessary delay in downloading a document is a penalty from a user’s perspective. It is possible to provide both a graphic-intensive page and a non-graphical page but this would mean an extra page to maintain.

This is not to say that larger images should not be used on the site. There are situations where graphics or images are necessary especially if they are ‘content’ images. There are decisions and legislation which require the use of images to convey the appropriate meaning. For example, in a trade mark case, it is necessary for the trade mark in question which is part of a decision to be available as an image online. This provides the context for the decision. In fact, a decision may include a number of graphics dealing with possible trade mark infringements. Also, in the case of some acts, formulae need to be expressed as an image. This is problematic for users who rely on non-graphical based systems. While work is underway for a mark up language to handle mathematical formulae which allows text based system to process the details, it is still more common for them to be converted to a graphic and displayed on a page as an image.

Image maps affect site level usability in the sense that there are navigational problems associate with using them. Image links do not provide visual cues for the user that the links have been traversed since they do not change colour after the user clicks them (User Interface Engineering; 1996). Text based browsers will have problems dealing with image maps and extra programming effort is required to make this work and thus increases the cost of maintenance.

The current use of animation on web sites ‘walks a fine line between added value and aggravation’ (Vaughan; 1996). Animations are more of a distraction than an aid from the point of view of a web searcher. It is highly likely that the user will be distracted from the information gathering process. Also, some less technically competent users may decide to wait for the ‘image’ to finish downloading and it may be a while before the user realises that this will not happen (User Interface Engineering; 1996). Animations are purely graphically oriented and thus will be problematic for those using text based browsers. Generally, they do not add meaning to the page.

4.4 Metadata and metatags
Metadata refers to data about data or in the web context, metadata is ‘machine understandable information about web resources or other things.’ (Berners-Lee; 1997.) It has been suggested that metadata has the potential to be used by search engines to increase the quality of information retrieval and resource discovery on large, widely distributed networks such as the Internet (Wood; 1997). From AustLII’s perspective, we are interested in the resource implications of the implementation and maintainability of a system for metadata storage and retrieval.

There is a push especially among large government agencies for the full deployment of a metadata scheme. It should be noted that essentially, government agencies prepare their own materials and thus maintain overall control of the content. This will at least provide an opportunity for metadata to be inserted, if appropriate, at source. However, AustLII receives data from many different sources over which it has no control. Attempting to incorporate metadata manually for an organisation like AustLII would be too resource intensive since over 1.5 million pages (as at July 1999) are involved. This is especially the case when attempting to ‘catalogue’ the resources used in the same way as a library catalogue.

One implementation scheme of metadata would be to incorporate the information in the HTML documents using <META> tags that are based on a content encoding scheme. However, due to the potential abuse of metadata, some search engines will not even index the information held in the <META> tags. For any metadata scheme to work effectively, if at all, there needs to be some standards in terms of content encoding schemes which take into account of resource implications. This is especially true for courts and tribunals which may have different systems in place. Metadata may be captured in different ways in the sense that the proper use of consistent styles in decisions of courts and tribunals would have provided a great deal of metadata to be able to enhance the functionality of the documents.

AustLII does use a limited form of metadata which is either generated automatically during the markup process or is inherent in the resource itself. Currently, the <TITLE> tag information is used for searching and displaying purposes. In the case of decisions, the decision date is also kept. Some of the benefits of using metadata may be obtained by using a more ‘intelligent’ full-text searching mechanism with an appropriate ranking algorithm. This may be a more practical alternative for the time being while more elements of metadata may be incorporated over time.

Most considerations of metadata have been focused on improving the quality of search results at considerable expense. However, from the perspective of accessibility and usability in relation to viewing, it is clear that the most popular versions of browsers do not make use of any metadata that is contained on web pages. This adds further to the opportunity cost of maintaining a complicated set of metadata when there is very limited or no support from the client end.

While fully structured materials with differentiated layout, complicated metadata and ratings mechanisms can be used, we believe that a simple approach can be utilised for maintaining ‘universal web access’ and still be practicable within the various constraints faced by AustLII. 
4.5 Citation standards and improving the source
4.5.1 Guidelines for uniform production of judgments
Over the last couple of years, there has been considerable interest from courts and tribunals throughout Australia to adopt a convention for citing cases and decisions which does not depend on a particular medium or a particular publisher or vendor. The citation is assigned by the court or tribunal concerned. The High Court of Australia, Federal Court of Australia, Family Court of Australia as well as Supreme Courts of all the states and territories have adopted this convention. The medium neutral citation is based on the names of the parties, the year of the decision, the designator of the court or tribunal and a decision number. For example, a decision from the High Court of Australia may be cited as: Sue v Hill [1999] HCA 30. 

For its part, AustLII has actively participated in the development and promotion of the use of medium neutral citation to all courts and tribunals. Individual courts and other standards bodies have produced guidelines and recommendations in relation to the use of medium neutral citation for decisions. The recently released AIJA Guide to Uniform Production of Judgments -<http://www.austlii.edu.au/au/other/col/1999/1/> provides further impetus for the development of standards beyond citation into other standards such as the use of consistent styles and ‘content tagging’ of the actual decisions (Olsson; 1999). Greater participation and consideration by the courts and other interested bodies in relation to standards will improve the quality of the data at source. As a result, organisations such as AustLII will be able to add value and make better use of the data. This in turn will make the materials more accessible and usable.

4.5.2 Transparency and consistency
The willingness of the courts and tribunals in Australia to adopt a medium and vendor neutral citation means that not only will users be able to cite decisions as they are made available on the Internet or on any other type of medium, it will also provide a mechanism for AustLII to improve on the transparency and consistency of its links structure. It is now possible for some databases to provide a greater accuracy and precision of the reference being cited. For example, in the Supreme Court of Victoria database, paragraph 30 of R v Coombe [1999] VSCA 94 can be precisely linked to at: 

<http://www.austlii.edu.au/au/cases/vic/VSCA/1999/94.html#para30>.

As can be seen from the example above, the URL for the reference resembles the medium neutral citation assigned by the Court. This enhanced level of accessibility and usability is derived from the Court adopting the medium neutral citation mechanism as well as the use of consistent styles in its decisions so that paragraphs can be identified during the conversion and mark up process.

4.6 HTML2, HTML3.2, HTML4 and XML
The success of the Web is mainly due to the fact that it provides authors with a cheap and easy way of distributing electronic documents to a worldwide audience. The basis for the transmission of documents on the Web has been HTML (Hypertext Markup Language) which is ‘a simple markup language for creating hypertext documents that are platform independent’. HTML has focused on ease of use and several versions of the HTML specifications have evolved. These have been mainly due to the pressures from the creators of the browser software. Traditionally, HTML was supposed to separate the structure from the layout of a document. It was supposed to be left to the browser to display the contents within the tags. However, the desire to control the presentation of web pages has resulted in a number of ‘format’ tags being introduced into the HTML specification or extensions to the HTML specification. This is most evident in the HTML 3.2 -<http://www.w3.org/TR/REC-html32.html> version of the specification.

The HTML 2.0 <http://www.w3.org/MarkUp/html-spec/>specification, which reflected the state of play as at June 1994, is the baseline standard for all browsers available today. AustLII has tried to select tags from this version of the HTML specification as they will be displayed by most browsers. The current standard, HTML 4.0 <http://www.w3.org/TR/REC-html40/>, does have some accessibility tags as part of its specification. Some of these may be appropriate provided they degrade gracefully for older browsers.
On the horizon, there is an emerging standard known as XML (Extensible Markup Language - <http://www.w3.org/XML/>) which is supposed to address the limitations of HTML and will be more flexible and extensible. The extensibility feature of XML will allow new tags to be defined as needed and allow data to be modelled to a greater level of complexity. Perhaps, this will provide an opportunity for a common set of XML tags to be developed for courts and tribunals in Australia and one set developed for legislative materials. Also, applying appropriate XML schemas may be a more appropriate approach in capturing and maintaining metadata about documents than using the <META> tag scheme of HTML. For example, some of the new backend applications to be used by AustLII are using XML as the data exchange format. The use of XML will provide greater functionality to the server and client software. The media independence of XML allows the same content to be published in multiple media and thus makes the information more accessible and usable by different browsing technology. While XML shows a lot of promise for the future of information exchange, the extent and compatibility to which it will be supported by the new 5.0 browsers remains to be seen.

5. Conclusion
In this paper, we have endeavoured to show that there is virtue in simplicity. We have considered a number of accessibility and usability issues with an AustLII perspective. As Terry Sullivan points out (Sullivan; 1999, p42): 

•	Simpler is more stable and less prone to error.
•	Simpler is more compatible.
•	Simpler is easier to maintain.
•	Simpler is easier to use.

We have presented our views in relation to a number of web technologies and why they may or may not be appropriate for achieving AustLII’s objective of maximising public access to legal information. We have also shown the benefits of adhering to standards in terms of general web standards as well as more legal specific standards. Ultimately, it is up to the producers of information as well as users of information to work together in producing consistent and well-structured documents as the Web moves from being a mechanism for information dissemination to a mechanism for information exchange.

References
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