Position statements, bundles & witness statements — presenting your evidence properly

REVIEWED BY: Sean McNamara on 2026-08-27

The three documents litigants in person most often get wrong

1. Position statement

A short document (usually 1–2 sides) filed before a hearing saying: what you want, your response to the other side's position, and what order you're asking for. Judges read it first — make it headings, dates and clarity, never emotion. Keep it factual.

2. Witness statement

Your signed, dated statement of the facts you rely on, numbered paragraph by paragraph. Content rules: first-hand knowledge only (what you saw/heard/did — not gossip), chronological, exhibits labelled and referenced ("I refer to the message at page A12"). In most family cases your statement stands as your evidence-in-chief — anything not in it is hard to add later.

3. The bundle

For hearings, the court orders a paginated bundle (Practice Direction 27A): every document the court needs, in an agreed order, page-numbered, served on all parties by a deadline. As a litigant in person you may have to build it — a chronology and an index are essential. Late or messy bundles waste hearing time and irritate judges.

Practical tips

  • Never attach everything — include what's relevant to the issues the court must decide
  • Number every page; reference documents by page number in your statement
  • Disclose what harms you too — hiding documents the other side has destroys credibility
  • Serve documents the way the rules require (see our service guide)

Official links

  • Practice Direction 27A (bundles): https://www.justice.gov.uk/courts/procedure-rules/family/practice_directions
  • https://www.gov.uk/looking-after-children-divorce

This page is general information, not legal advice. YourFamilyCase.co.uk is an independent information directory and is not affiliated with HMCTS or gov.uk.

Content verified against the official HMCTS court directory, gov.uk forms and fees pages, and the professional body registers (SRA, FMC, Bar Council). Last reviewed September 2026.

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