Witness statements in family cases — structure, exhibits and the statement of truth

REVIEWED BY: Sean McNamara on 2026-08-30

Your witness statement is your evidence. At a fact-finding or final hearing, the judge decides largely on what's in the statements — yours and the other side's. Writing one well is a skill every litigant in person can learn. This guide covers structure, exhibits and the formal requirements. It is general information, not legal advice.

What a witness statement is

A signed, dated, formal document containing the evidence you would give orally
Filed with the court and served on every other party by the deadline in the directions order
In most family hearings you adopt it: at the start of your oral evidence you confirm it's true, and it stands as your evidence-in-chief — so everything important must already be in it
Ends with a statement of truth: "I believe that the facts stated in this witness statement are true." A false statement can lead to proceedings for contempt

Structure that judges respect

1. Heading block: court name, case number, parties, "Witness Statement of [full name]", the hearing it's for 2. Opening: "I am the [applicant/respondent/father of…]. I make this statement in support of… / in response to the statement of…" — one or two sentences 3. Background (only what's needed): dates of relationship, children's names and DOBs, key events — a short chronology 4. The evidence, chronologically: paragraphs numbered throughout; date-stamped events; each allegation tied to a time, place and source 5. What you're asking for: a closing section connecting your evidence to the order you seek 6. Exhibit list and the statement of truth, signed and dated

Writing rules

First person, past tense: "On 3 March 2026 I collected Tom from school…" — not "the respondent is a liar"
Number every paragraph — it's how everyone refers to your evidence ("paragraph 14 of the father's statement")
One event per paragraph, with date, place, who was present
Distinguish memory from inference: "I saw X" versus "I believe Y because…" — judges weigh direct observation far above speculation
No argument, no adjectives: the statement is for facts; argument belongs in your position statement. "He screamed at me for an hour" is evidence; "he is an aggressive bully" is not
Address the other side's evidence where directed — but factually, point by point
Child-focused where it matters: connect events to the child's experience and needs

Exhibits

Attach supporting documents as exhibits: label them "JS1", "JS2" (your initials + number), each with its own cover page ("Exhibit JS3 — this is a bundle of text messages between me and the respondent between 1 and 10 May 2026")
Paginate every exhibit; reference them precisely in the statement ("Exhibit JS3, page 7, message of 3 May at 14:22")
PD27A 2026: messages, emails, social media, voice notes and photographs cannot go loose in the court bundle — they reach the court as exhibits to statements, properly labelled
Keep the originals (the phone, the letters) — you may need to produce them

Length and deadlines

Long is not strong: judges prefer tight, complete, credible. For most hearings, 5–15 pages is plenty; fact-findings may justify more
Deadline discipline: a brilliant statement filed late can be excluded, and it always damages you. If you can't meet the deadline, apply for an extension before it passes
Serve the other parties as your directions order requires — filing and service are separate obligations

If you're responding to allegations

Deal with allegations specifically: admit what's true, deny what's false, explain the rest — a blanket denial persuades no one
Put your exculpatory evidence in: documents, witnesses (name them and say what they will say), records
Note what the other side must prove; allegations against you are for them to evidence, on the balance of probabilities
Where allegations are true but need context, give the context without excusing — honesty about the past is the strongest platform for the future

At the hearing

You'll be asked to confirm your statement is true — your oral evidence then supplements it (you can't normally read it out; it's already in)
Cross-examination tests the statement: keep answers consistent with it; if you misremember, say so rather than bend
Bring your exhibits and the originals

Official links

YourFamilyCase.co.uk is an independent information directory — we are not affiliated with, endorsed by, or connected to HMCTS or gov.uk. This page is general information and is not legal advice.

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.