How to prepare a court bundle as a litigant in person

Court bundles are one of the most practical challenges for litigants in person. The court expects a properly prepared bundle for almost every contested hearing. A badly prepared bundle can frustrate the judge, slow the hearing and leave you fumbling to find documents while the judge waits.

This guide explains what a court bundle is, what should be in it, how it should be ordered and how to prepare one to the standard the court expects.

What is a court bundle?

A court bundle is the file of documents that the judge, the parties and any advocates will use during a hearing. It is the single reference document for the case. Every document the court might need to look at should be in it.

Bundles are usually prepared by the applicant (or by an agreed party where the case is more complex). Where one side is represented and the other is a litigant in person, the represented party often prepares the bundle.

If you are a litigant in person and the other side is also unrepresented, responsibility for the bundle falls to whichever party is more easily able to prepare it. In practice this often means the applicant.

The rules about bundles

The standard family court rules on bundles are set out in Practice Direction 27A and the Family Procedure Rules. The same broad principles apply across civil and family proceedings:

• The bundle should contain only documents that are relevant to the hearing
• It should be paginated continuously throughout
• It should be indexed so anyone can find a specific document quickly
• It should be in a logical order
• Any new documents added later should be inserted in the right place, not appended at the back
• The bundle should be filed at court and served on the other party in advance of the hearing

What should be in a court bundle?

The contents depend on the hearing, but most family court bundles include:

Section A: Preliminary documents

• Case summary
• Position statements
• Chronology
• List of issues

Section B: Applications and pleadings

• The original application form (D8, Form A, C100 etc.)
• Any subsequent applications (D11, C2 etc.)
• Any acknowledgment of service or response

Section C: Orders

• All previous court orders in date order, oldest first

Section D: Statements and evidence

• Witness statements with exhibits
• Sworn statements
• Affidavits

Section E: Expert and other reports

• CAFCASS reports
• Section 7 reports
• Expert reports
• Medical or psychological reports

Section F: Correspondence

• Only relevant correspondence. Not everything you have ever sent

Section G: Miscellaneous

• Anything else relevant to the hearing

For financial remedy hearings, separate sections for Forms E, valuations, ES1 and ES2 may also be needed.

What should not be in a bundle?

The temptation, especially for litigants in person, is to include everything. Resist it. The court has been clear that bundles should contain only relevant material. Excessive bundles waste the court's time and increase costs.

Things that usually do not belong in the bundle:

• Routine correspondence about hearing dates or admin
• Old emails about issues that have been resolved
• Duplicate copies of documents
• Documents from unrelated proceedings
• Background documents that are not directly relevant
• WhatsApp messages or social media screenshots unless they directly support a specific point

How to paginate a bundle

Pagination is one of the most common problems with litigant in person bundles. The rules are simple:

• Number every single page in the bundle
• Use one continuous number sequence from the first page to the last
• Pages can be numbered manually, by stamp or by digital insertion
• The index must show the page numbers for each document

If a document is added later, you can use "a", "b", "c" suffixes to insert it in the right place without renumbering. For example, if a new witness statement goes between pages 47 and 48, it becomes 47a to 47e.

The index

Every bundle needs an index at the front. The index lists each document in the bundle with its page reference. A good index:

• Uses the same section structure as the bundle
• Lists documents in the order they appear
• Gives the document name, date and starting page number
• Fits on a single page where possible

Paper or electronic bundles?

Most family courts now accept electronic bundles, usually as a single PDF. The judiciary's preferred approach for electronic bundles includes:

• A single PDF file, not multiple files
• Internal hyperlinks from the index to each section
• Bookmarks for each section
• OCR text recognition so the document can be searched
• Continuous pagination across the whole document

For paper bundles, use a ring binder with section dividers and ensure the binder can be opened flat. Most judges and barristers prefer A4 binders rather than oversized ones.

When should the bundle be filed?

The court usually expects the bundle to be filed and served on the other party several working days before the hearing. The exact deadline depends on the type of hearing and any specific directions. For most family court hearings, two to seven days before is the norm.

Filing a bundle the day before a hearing is a common cause of judicial frustration. Build in time for the court office to process the bundle.

How to handle disagreement about bundle contents

Where the parties disagree about what should be in the bundle, the usual approach is:

• One party prepares a draft index
• The other party responds with proposed additions or removals
• The parties try to agree
• If they cannot agree, the matter is raised at the hearing or addressed by application

Most disagreements are resolved by accepting that contested documents can be included with the judge then deciding their relevance.

Common mistakes in litigant in person bundles

Including too much

A bundle of 800 pages for a routine directions hearing tells the judge you do not understand what is relevant.

Inconsistent pagination

Pages numbered in one section and not another, or restarted in each section, is the most common formatting problem.

No index

Without an index, the bundle is unusable.

Wrong order

Documents jumbled together rather than grouped by section makes it impossible to find anything quickly.

Late filing

Filing the bundle the morning of the hearing is a major problem and may lead to the hearing being adjourned at your cost.

Missing the witness statement

Your own evidence not being in the bundle defeats the purpose entirely.

When to take help

Many litigants in person prepare bundles themselves and do a competent job. For complex cases, hearings where the bundle is large or where you want to be sure the bundle is to professional standard, paying a barrister or paralegal to review or prepare the bundle is usually money well spent.

A direct access barrister can prepare or review your bundle, advise on what to include and ensure it meets the court's expectations.

Want a barrister to review your case?

Whether you need full representation at a hearing or just a one-off conference to take advice, our team can match you with the right specialist quickly. There is no charge for the initial enquiry. Tell us what you are dealing with and we will arrange a fixed-fee quote.