Guidance note: court bundles
This Guidance Note was updated 2 March 2026. The law or procedure may change and members should always check the up-to-date position.
The preparation of court bundles is governed by Practice Direction 27A of the Family Procedure Rules 2010. It was issued “to achieve consistency across the country in the Family Court and the Family Division of the High Court in the preparation of court bundles”. The latest version of PD27A was published 2 March 2026.
It is vital that all practitioners familiarise themselves with this practice direction and members must ensure that they keep themselves up to date with the current guidance.
The Office of the President of the Family Division has also published guidance for litigants in person on preparing court bundles for family proceedings (2 March 2026) .
Failure to comply
Chapter 3 sets out the penalties for failure to comply with this Practice Direction – this may result in the Court removing the case from the list or putting the case further back in the list and may also result in an adverse Costs Order or “Wasted Costs Order” being granted.
Preparation of the bundle
Chapter 4 provides for e-bundles being the norm (4.2), with paper bundles only being appropriate in “exceptional circumstances”. Even if an e-bundle is filed and served, a paper bundle must also be provided to the Court for use by the Judge, by a witness and/or by a litigant in person who cannot access e-bundle or where there is a realistic possibility of the witness giving evidence in person in Court (4.3). If however electronic equipment is provided on which the bundle can be viewed, the requirement to provide a paper bundle can be dispensed with.
The default position is that the applicant should prepare, file and serve the bundle (4.5) however, if the applicant is a litigant in person but the respondent is legally represented, then the legally represented respondent must prepare, file and serve the bundle (4.6).
If however, all parties are litigants in person, HMCTS can be directed to prepare and make the bundles available (4.7).
Contents of the bundle
Chapter 5 sets out details as to what should be included in the bundle. Practitioners must be aware that the bundle must only contain copies of those documents “which are relevant to the hearing and which it is necessary for the Court to read or which will actually be referred to during the hearing”. Copies of the following documents must not be included in the bundle unless the Court directs otherwise (5.2):
a) correspondence (including letters of instruction to experts and correspondence between legal representatives);
b) copies of emails, text messages, WhatsApp messages or any form of social media communications;
c) voice notes or other recordings;
d) bank and credit card statements and other financial records;
e) notes of contact visits;
f) foster carer logs;
g) social Services files (with the exception of any assessment being relied on by any of the parties);
h) photographs.
However, please note that “this does not prevent the inclusion in the bundle of specific documents which it is necessary for the court to read, or which will actually be referred to during the hearing”.
Financial remedy proceedings
Chapter 6 sets out the specific requirements for preparing the bundle in financial remedy proceedings. Practitioners must ensure they are fully conversant with this chapter if they undertake this type of work.
6.2 sets out how the bundle should be arranged and paginated.
6.3 provides for the documents to be included in the bundle in financial remedy proceedings:
a) preliminary documents;
b) applications and orders;
c) statements and affidavits comprising:
i) Forms E;
ii) replies to questionnaires;
iii) parties statements or affidavits, , which must be dated in the top right corner of the front page, but without exhibiting or duplicating documents referred to in paragraph 5.2;
d) any experts reports and other reports; and
e) any other relevant documents, divided into sections as may be appropriate.
The practice direction recognises that preliminary documents will generally be filed later than the rest of the bundle and states at 6.5 that they should be numbered consecutively using Arabic numbering and should be numbered separately to the rest of the bundle.
6.6 The preliminary documents referred to at 6.3 (a) are:
a) Form ES1.
b) FM5.
c) Form ES2.
d) An up to date chronology.
e) The parties’ position statements.
f) A list of essential reading for that hearing.
g) A time estimate (where the hearing is expected to be two hours or more).
Each party should prepare their own set of preliminary documents (6.4) and should be as short and succinct as possible (6.7).
Forms ES1 and ES2 must set out the parties respective positions on issues in dispute. The chronology and reading list must, in the case of a final hearing consist of a single document in the form agreed by all parties. Where the parties disagree as to content, then the fact of the disagreement and their differing contentions must be set out at the appropriate places in the document (6.9).
A new bundle must be prepared, filed and served for each subsequent hearing (6.10).
The preparation of position statements is governed in 6.11–6.14. The following page limits apply depending upon the type of hearing (6.12):
- First appointment – 6 pages
- Any other interim hearing – 8 pages
- FDR – 12 pages
- Final hearing – 15 pages
Please note that all of the above page limits include attached schedules.
Skeleton arguments within position statements which have been allocated to a High Court Judge shall continue to be governed by the current Statement on the Efficient Conduct of Financial Remedy hearings (6.15).
All other family proceedings
Chapter 7 applies in all proceedings except financial remedy proceedings however practitioners should note that 7.4–7.7 applies to public law proceedings.
Unlike the bundle for financial remedy proceedings, the bundle prepared in all other proceedings must contain an index at the beginning which should not be paginated (7.2(b)). The contents of the bundle must be paginated individually using the Bates numbering system (7.2(d)).
The contents of the bundle under 7.3 is as follows:
a) preliminary documents;
b) applications and orders;
c) statements and affidavits;
d) care plans;
e) any experts reports or other reports (including those of a children’s guardian);
f) any relevant medical records;
g) any relevant police disclosure;
h) in public law proceedings, where the bundle is for a case management hearing, a copy of the birth certificate of the child to whom the proceedings relate or an equivalent document at; and
i) other relevant documents divided into sections as may be appropriate.
7.6 sets out the documents to be included in a bundle in public law proceedings:
a) an up-to-date case summary of the background to the hearing;
b) a statement of the issue or issues to determined at (i) at that hearing and (ii) at the final hearing;
c) a position statement by each party including a summary of the order or directions sought by that party (i) at that hearing and (ii) at the final hearing;
d) a skeleton argument;
e) an up-to-date chronology;
e) a list of essential reading for that hearing; and
f) where a hearing is an evidential hearing, a contested hearing or a final hearing, a witness template.
7.9 provides that the preliminary documents must usually be prepared by the applicant. If however the applicant is a litigant in person, the preliminary documents referred to in 7.10 (a), (b) and (f) must be prepared by a represented party.
7.10 provides details of the preliminary documents that should be included in proceedings other than public law proceedings:
a) an agreed up-to-date case summary;
b) an agreed statement of the issues to be determined (i) at that hearing and (ii) at the final hearing.
c) Any form FM5 that has been filed in the proceedings;
d) a position statement by each party including a summary of the order or directions sought by that party (i) at that hearing and (ii) at the final hearing;
e) a skeleton argument;
f) an agreed up-to-date chronology;
g) an agreed essential reading list for that hearing; and
h) where a hearing is an evidential hearing, a contested hearing or a final hearing, a witness template.
Position statements should be no longer than 3 pages in length unless the court accepts that the case is complex (7.18).
Length of documents
Chapter 8 sets out the number of A4 pages/sheets for preliminary documents as follows:
- Case summary – 6
- Statement of issues – 2
- Position statement (as provided in paragraph 6.10 and 7.17)
- Chronology – 10
- List of essential reading – 1
- Witness statement or affidavit (exclusive of exhibits) – 25
- Experts or other report – 40 (including executive summary at the beginning of no more than 4 pages)
- Care plan – 10
Core bundles
Chapter 9 refers to core bundles if these are directed by the court.
Authorities
Authorities which are to be relied on must be contained in a separate composite bundle (Chapter 10.2).
Format of the bundle
Chapter 11 sets out the guidance for the format of e-bundles, whilst Chapter 12 sets out the requirements for the preparation of paper bundles.
Timetable for preparing and filing the bundle (both paper and e-bundles)
Under Chapter 13:
- Parties must seek to agree the contents of the bundle within 7 working days of the hearing;
- The agreed bundle must be filed and served within 5 working days of the hearing;
- The preliminary documents if not already filed and served must be filed and served on all parties and the Court by the person responsible for preparing the bundle by 11a.m. on the working day before the hearing. If the hearing is before a High Court Judge and the name of the Judge is known, the preliminary documents must also be sent by email to the Judge’s Clerk.
Filing of bundles
Chapter 14 sets out specific directions for filing of e-Bundles.
Chapter 15 provides guidance for the filing of paper bundles.
Chapter 16 sets out the additional requirements for filing bundles with the Family Division or Family Court cases being heard at the Royal Courts of Justice.