Because recorded (old/closed) files are background reference — they are consulted if needed but are not the primary document being acted upon. The current file is the decision-making document and should be on top.
Source: CSMOP Para 24
Why are recorded files placed below current files in the arrangement?
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This answer is for informational purposes only and does not constitute legal advice. Always refer to the original rules and consult competent authorities for official interpretation.