"Infra" means "Below". So, why use "Infra"?
Reason #1: "Infra" has a specific legal meaning, while "Below" can be ambiguous;
Infra always means a subsequent part of text (ie, "below this paragraph").
Below usually means a subsequent part of text (ie, "below this paragraph").
However, sometimes, Below means a lower court
(ie, "the trial court").
Reason #2: "Infra" is a short/simple word (compared to other latin terms);
Reason #3: Using "Infra" will indicate that you are willing to fight to the end.
Fighting to the end ≈ going through the appellate process.
Example A (An Ambiguous use of "Below"):
"1. The court below said Appellant deserved X-Y-Z, but Appellant deserved A-B-C (see 20, below)."
"25: Appellant deserves A-B-C because of blah blah blah..."
Analysis:
This passage used the word "below" twice in one sentence. The first time it meant the trial court; and the second time it meant a succeeding portion of the same document.
Problem:
Ambiguity.
Moreover, every subsequent citation of that passage will increase confusion.
Solution:
Use "infra" instead (see Example B, infra)
Example B (Clear use of "Below" and "Infra"):
"1. The court below said Appellant deserved X-Y-Z, but Appellant deserved A-B-C (see 20, infra)."
"25: Appellant deserves A-B-C because of blah blah blah..."
Analysis:
This passage cites itself; while making clear that its substance comes from a lower court.
Benefit:
Clear. Simple.
Both the appellate court and the trial court will understand what you're saying.