Court bundles

Court bundles are an integral element to family court proceedings as they contain a great deal of information that relate to a particular dispute. This information page will provide further advice on what the bundle is, who is responsible for preparing the bundle, what should be included in the bundle and the timetable for preparing and lodging the bundle. 

What is a court bundle?

Practice Direction 27A of the Family Procedure Rules provides guidance on court bundles.  

A court bundle is a folder(s) which contains copies of all the documents which are considered relevant to a court case. 

How should a bundle be formatted?

The bundle shall be contained in one or more A4 size ring binders or lever arch files (each lever arch file being limited to 350 pages).

All ring binders and lever arch files shall have clearly marked on the front and the spine:

• the title and number of the case;
• the court where the case has been listed;
• the hearing date and time;
• if known, the name of the judge hearing the case; and
• where there is more than one ring binder or lever arch file, a distinguishing letter (A, B, C etc).

Who is responsible for preparing the bundle?

It is the responsibility of the person in the position of applicant to prepare the bundle. However, if that person is a litigant in person, it is the responsibility of the first listed respondent who is not a litigant in person. Where all the parties are litigant in person none of them shall, unless the court otherwise directs, be obliged to provide a bundle. 

What are the contents of the bundle?

The documents in the bundle shall be divided into separate sections (each section being separately paginated and in chronological order (earliest first)) as follows:

A. preliminary documents (see below) and any other case management documents required by any other practice directions;

B. applications and orders;

C. statements and affidavits;

D. care plans (where appropriate);

E. experts’ reports and other reports (including those of a guardian, children’s guardian or litigation friend); and

F. other documents, divided into further sections as may be appropriate.

The index

An index is a list which is included at the beginning of the bundle that sets out what is in the bundle and specifically where each document can be located.

Please click here to view a template index.

Preliminary documents

At the commencement of the bundle there shall be inserted the following documents (the preliminary documents):

• an up to date case summary of the background to the hearing confined to those matters which are relevant to the hearing and the management of the case and limited, if practicable, to four A4 pages;
• a statement of the issue or issues to be determined (1) at that hearing and (2) at the final hearing;
• a position statement by each party including a summary of the order or directions sought by that party (1) at that hearing and (2) at the final hearing;
• an up to date chronology;
• skeleton arguments, if appropriate; and
• a list of essential reading for that hearing.

Each of the preliminary documents shall be as short and succinct as possible and shall state:

• when it was prepared; and
• the date of the hearing for which it was prepared. 

What should not be included in the bundle? 

The bundle shall contain copies of only 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. In particular, copies of the following classes of  documents must not be included in the bundle unless specifically directed by the court:

• correspondence (including letters of instruction to experts);
• medical records (including hospital, GP and health visitor records);
• bank and credit card statements and other financial records;
• notes of contact visits;
• foster carer logs;
• social services files (with the exception of any assessment being relied on by any of the parties);
• police disclosure.

Where the nature of the hearing is such that a complete bundle of all documents is unnecessary, the bundle (which need not be repaginated) may comprise only those documents necessary for the hearing, but the summary of the background (see under 'Preliminary Documents') must commence with a statement that the bundle is limited or incomplete; and the bundle shall, if reasonably practicable, be in a form agreed by all parties.

What if there is a disagreement regarding the contents of a bundle? 

Parties can ordinarily reach an agreement regarding what should be included in the bundle. If there is a disagreement, a summary of the points on which the parties disagree should be included. The aggrieved party can also consider preparing a supplemental bundle which includes the documents which are under dispute. 

What is the timetable for preparing and lodging the bundle?

The bundle or index where appropriate shall be served on:

• All other parties: A paginated index shall be provided no less than four working days before the hearing. The other parties can put together their own bundle from the index. 
• Legal representatives: A paginated bundle shall be provided no less than three working days before the hearing
• Court: A paginated bundle (excluding preliminary documents) shall be provided no less than two working days before the hearing, or at such other time specified by the court. Any preliminary documents must be lodged with the court by 11am the day before the hearing.

How do I lodge the bundle? 

The bundle shall be lodged to the court which is handling the case unless otherwise specified by the court.  

Any bundle sent to the court by post, DX or courier shall be clearly addressed to the appropriate office and shall show the date and place of the hearing on the outside of any packaging as well as on the bundle itself.