California, United States of America
The following excerpt is from E. F. Hutton & Co. v. City National Bank, 149 Cal.App.3d 60, 196 Cal.Rptr. 614 (Cal. App. 1983):
1 Code of Civil Procedure section 472d requires the trial judge to specify the grounds upon which the ruling is based when the demurrer is sustained. This requirement is satisfied if the judge makes specific reference to the appropriate paragraphs of the demurrer or the supporting points and authorities. Here, the trial judge did not satisfy this requirement, but it does not appear that plaintiff's lawyer requested a statement or a recital of specific grounds. Failure to demand or to point out to the court the absence of the specific grounds waives the irregularity. (Cohen v. Superior Court (1966) 244 Cal.App.2d 650, 655, 53 Cal.Rptr. 378.)
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