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.
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 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 contents depend on the hearing, but most family court bundles include:
For financial remedy hearings, separate sections for Forms E, valuations, ES1 and ES2 may also be needed.
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:
Pagination is one of the most common problems with litigant in person bundles. The rules are simple:
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.
Every bundle needs an index at the front. The index lists each document in the bundle with its page reference. A good index:
Most family courts now accept electronic bundles, usually as a single PDF. The judiciary's preferred approach for electronic bundles includes:
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.
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.
Where the parties disagree about what should be in the bundle, the usual approach is:
Most disagreements are resolved by accepting that contested documents can be included with the judge then deciding their relevance.
A bundle of 800 pages for a routine directions hearing tells the judge you do not understand what is relevant.
Pages numbered in one section and not another, or restarted in each section, is the most common formatting problem.
Without an index, the bundle is unusable.
Documents jumbled together rather than grouped by section makes it impossible to find anything quickly.
Filing the bundle the morning of the hearing is a major problem and may lead to the hearing being adjourned at your cost.
Your own evidence not being in the bundle defeats the purpose entirely.
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.
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.