Short answer. No. Section 9 of Rule 8 makes it sufficient, when pleading an official document or official act, to aver that the document was issued or the act was done in compliance with law — without needing to allege the detailed technical steps of that compliance.
What the law says
In pleading an official document or official act, it is sufficient to aver that the document was issued or the act was done in compliance with law.
Rule 8, Section 9 — Official document or act. Read the full provision →
A simplified standard for official documents and acts
Section 9 addresses situations where a pleading references something done by a government office or officer — an official document that was issued, or an official act that was performed. Rather than requiring the pleader to walk through every procedural step that led to that document or act, the section makes it sufficient to aver that the document was issued or the act was done in compliance with law, sparing the pleader from having to reconstruct an agency's internal process in the complaint itself. This simplified standard binds whoever is pleading the official document or act into the case, whether a private litigant citing a government-issued permit or a party invoking a court's own prior order; it is not limited to pleadings filed by or against a government agency itself.
Why this simplification makes sense
Official acts and documents typically involve internal government procedures that a private party pleading about them would have no direct knowledge of — the specific forms followed, internal approvals obtained, or officials who signed off along the way. Requiring detailed pleading of all of that would be impractical for someone outside the issuing agency. A general averment of compliance with law shifts the pleading burden to something the party can realistically know and state without needing access to the agency's own internal files. Nothing in Section 9 excuses the party from attaching the document itself where the underlying claim is founded on it; the simplification applies only to how the document's regularity of issuance is described in words, not to whether the document must be produced at all.
This does not foreclose a challenge
As with the general averment of conditions precedent under Section 3, this simplified standard governs what must be pleaded — it does not mean the compliance is beyond dispute. An opposing party who genuinely believes the official document was not properly issued, or the official act not properly done, can still contest that through appropriate denial and evidence, putting the matter at issue for proof even though the pleading requirement itself was minimal and did not demand a detailed narrative up front. The section simply reallocates who has to do the initial legwork of pleading, not who ultimately bears the burden of proving the point if it is genuinely contested.