English 1b3 Are there rules No. This is a question of style rather than of grammar. There are many cases where all three forms are grammatical and in common use, so in these cases it's a matter of authorial preference.
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English 1b3Are there rulesNo. This is a question of style rather than of grammar. There are many cases where all three forms are grammatical and in common use, so in these cases it's a matter of authorial preference. My guess is that the form with the apostrophe is the least often chosen.