Skeleton arguments, chronologies and position statements — how to write them

REVIEWED BY: Sean McNamara on 2026-08-29

Three documents, three jobs

Before many family hearings — final hearings especially — you may be asked to file a position statement, a chronology, or a skeleton argument. They are not the same thing, and it helps to know which one you're being asked for:

Position statement — what you want and the outline of why. A short, plain-language snapshot of your stance filed ahead of a hearing (or handed to the judge on the day).
Chronology — the agreed or disputed sequence of events and court orders, in date order, so the judge can see the history at a glance.
Skeleton argument — your compact legal argument: the points you will make and the authorities (cases/law) you rely on, so the judge can read your case before you speak.

Position statement — format, length, what to include

Short and human. One to two pages is the norm. Write in numbered paragraphs and plain English. Include:

Your name, whether you're a litigant in person, and the hearing it's for (date and type)
What you're asking the court to do (the order you seek)
The key facts the court needs to know, briefly
The law or principle you rely on (in one or two lines — no need to quote at length)
Anything the other side has got wrong that you must correct

A position statement is your opening line, not your whole case — save detail for oral submissions and evidence.

Chronology — what goes in it

A table or list in date order, each entry one or two lines. Cover:

Orders made — every court order (give the date and what it said)
Key events — separation, applications, when the children last lived where, significant incidents relevant to the dispute
Proceedings — applications filed, hearings held, their outcome

Mark which entries are agreed and which are disputed (a short "agreed/disputed" column or a note). Keep it neutral and factual — no argument in a chronology; argument belongs in the skeleton. If only your side has filed one, label it as your version so the court knows the other party may not accept every line.

Skeleton argument — the case, concisely

The skeleton is where your argument lives. Keep it proportionate — often three to eight pages, but only as long as it needs to be. Structure it as:

1. Introduction — one paragraph on what the case is about and what you seek 2. Issues — the one to three questions the court actually has to decide 3. Relevant facts — the facts that matter to those issues (cross-referenced to the bundle/evidence where possible) 4. Law and submissions — your argument on why the law supports your side, citing any case or statutory provision you rely on (a case name and the point it stands for is enough; quote only the key sentence) 5. Conclusion / order sought — what you ask the court to do

Follow the chronological spine: put documents in date order, number your paragraphs, and keep every point short. A judge who can follow your skeleton in ten minutes reads you as prepared and credible.

How litigants in person write them competently

Be concise. Courts value a short, clear document far above a long, muddled one. If it can be one page, make it one page.
Follow any direction letter. If the court or the other side has specified a date to file by, send it even late — a late but real document beats none.
Use numbered paragraphs and one idea per paragraph; judges refer to "paragraph 12", not "the bit about the school runs".
Stay factual in the chronology, argumentative in the skeleton — don't merge the two.
Refer to the bundle (page numbers) where you can: it is the single most professional habit you can adopt as a LiP.
Be realistic about tone — measured and respectful writing reads better to a judge than long grievances. You are persuading the court that your position is reasonable.
If the paperwork feels overwhelming, a McKenzie friend can help you draft and organise (see our guide to using one well).

Official links

Position statements in the Family Court: https://www.gov.uk/
Family Procedure Rules — skeleton arguments and bundles: https://www.justice.gov.uk/courts/procedure-rules/family
What to expect in court: https://www.gov.uk/going-to-court/coming-to-court

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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