In Paper
Black's Law Dictionary · Henry Campbell Black, M.A. · 1910
Black's Law Dictionary
A term formerly applied to the proceedings in a cause before the record was made up.
3 Bl. Comm. 406 ; 2 Burrows, 1098.
Probably from the circumstance of the record being always on parchment The opposite of "on record."
1 Burrows, 322.