The McGill Guides recommends the neutral citation should be the main citation.
McGill Guide's Hierarchy of Sources
Neutral citations are used to identify a particular case but does not indicate where a case can be found. After the Style of Cause (name of the case), there are three parts:
1) Year 2) Abbreviation of the Court Decision 3) ordinal number
Online Database Services
These citations are referred to as main or parallel citations. They have the same status as unofficial reporters in the hierarchy of sources. Do not include the URL.
General Format
Style of Cause, Main Citation, Database identifier (abbreviation for online database if it is not obvious from the database identifier).
CanLII example
Westlaw example
Quicklaw example
If no neutral citation is available, the citation appears in the following order:
General Format
Style of Cause, Citation to a print reporter, Database identifier, Jurisdiction and/or court if necessary.
General Format
(Style of cause, date)