How to Prepare a Court Evidence Bundle: A Complete Guide

What Is a Court Evidence Bundle?

A court evidence bundle is a compiled, indexed, and paginated collection of all documents that the parties intend to rely upon at trial. It is the single most important document the judge will use to decide your case.

The requirements for trial bundles are set out in CPR Practice Direction 39A and, for multi-track cases, in the relevant court guide (such as the Queen’s Bench Guide or Chancery Guide). Even on the small claims track, where formal bundle requirements are relaxed, presenting your documents in an organised manner significantly assists the court.

The principle is straightforward: the judge needs to find any document, on any issue, within seconds. A well-prepared court evidence bundle makes this possible. A poorly prepared one creates confusion, wastes court time, and reflects badly on the party responsible for preparing it.

Who Prepares the Bundle?

The general rule is that the claimant is responsible for preparing the trial bundle, unless the court orders otherwise. This obligation applies regardless of whether the claimant is legally represented or a litigant in person.

The claimant must:

1. Agree the contents with the defendant in advance of preparation
2. Prepare the bundle in accordance with the court’s directions and the relevant practice direction
3. File the bundle with the court by the deadline specified in the directions (typically 7 days before trial on the fast track, or 3 to 7 days on the multi-track)
4. Provide copies to the defendant and any other parties

If the parties cannot agree on the contents, the claimant should include all documents they consider relevant and note any objections. The judge will resolve disputes about admissibility at trial.

What Goes Into the Bundle?

The contents of a court evidence bundle should include, in this order:

Section	Contents
A. Claim and Statements of Case	Claim form, particulars of claim, defence, any reply, any counterclaim, any amended statements of case
B. Court Orders and Directions	All orders made by the court, including allocation, case management, and any unless orders
C. Witness Statements	All witness statements of fact, in chronological order of the witnesses or grouped by party
D. Expert Reports	Any expert reports, joint statements, or answers to Part 35 questions
E. Disclosed Documents	Correspondence, contracts, invoices, photographs, financial records — the documentary evidence the case turns on
F. Miscellaneous	Any other documents referred to in witness statements or skeleton arguments, legal authorities (if directed)

Not every case requires all sections. A small claims track hearing for a debt of £3,000 might require only the claim form, defence, a few invoices, and some emails. A multi-track commercial dispute might run to several lever-arch files. The principle is the same: include everything the judge needs, exclude everything they do not.

Formatting and Presentation

The court expects bundles to meet specific formatting standards. These are not arbitrary — they exist to ensure that judges, who may handle dozens of bundles per week, can navigate your documents efficiently.

Pagination

Every page in the bundle must be numbered sequentially. Page numbering runs continuously through the entire bundle — do not restart numbering at the beginning of each section.

For bundles with multiple volumes, use the format: Volume 1, pages 1-250; Volume 2, pages 251-500.

The pagination must be:

• Clear and legible — stamped or printed in the bottom right corner
• Sequential — no gaps, no duplicate numbers
• Referenced consistently — when referring to a document in a witness statement or skeleton argument, cite the bundle page number (e.g., “see Bundle page 47”)

Index

The bundle must have an index at the front listing every document, its date, a brief description, and the page number where it can be found.

A well-structured index looks like this:

Page	Date	Document
1	15.03.2025	Claim Form (N1/OCMC)
5	15.03.2025	Particulars of Claim
12	02.04.2025	Defence
18	10.04.2025	Order of District Judge — (Allocation)
20	—	Witness Statement of [Claimant]
28	—	Witness Statement of [Defendant]
35	01.01.2025	Contract between parties
40	15.02.2025	Email: Claimant to Defendant re breach
42	22.02.2025	Email: Defendant to Claimant re response

The index is the first thing the judge reads. It sets the tone for how they experience your case. A precise, well-organised index signals a well-prepared party.

Dividers and Tabs

For physical bundles:

• Use section dividers with labelled tabs (A, B, C, etc.)
• Place documents in chronological order within each section
• Use a ring binder or lever-arch file — never loose papers or stapled bundles
• Ensure pages lie flat and are not obscured by the binding

For electronic bundles (increasingly common and sometimes required):

• Use PDF format with a hyperlinked index
• Apply electronic page numbering that matches the index
• Use bookmarks for each section and major document
• Ensure the file is searchable (OCR scanned documents if necessary)
• Keep the file size manageable — compress images where possible without losing legibility

The Small Claims Track: A Simplified Approach

On the small claims track, the formal bundle requirements of PD 39A do not apply. However, the judge still needs to see the relevant documents in an organised format.

For small claims hearings, prepare a simpler bundle:

• Statements of case (claim form, defence)
• Key correspondence — the 5 to 10 most important emails or letters, in date order
• Core documents — the contract, invoice, receipt, or other document at the heart of the dispute
• Photographs — if relevant (defective goods, property damage)

Even without formal requirements, paginate your documents and provide an index. Bring three copies to the hearing: one for the judge, one for the defendant, and one for yourself. This simple act of preparation distinguishes well-organised litigants from those who arrive with a carrier bag of unsorted papers.

Witness Statements in the Bundle

Witness statements should be included in the bundle in full. Each statement must:

• Be headed with the title of the proceedings and the claim number
• State the full name, address, and occupation of the witness
• Be expressed in the first person (“I saw…”, “I received…”)
• Set out facts within the witness’s own knowledge, not opinions or legal argument
• Contain numbered paragraphs
• Be signed and dated with a statement of truth

When referring to documents in a witness statement, use the bundle page reference: “I refer to the email dated 15 February 2025, at Bundle page 40.” This allows the judge to turn directly to the document while reading the statement.

CPR Part 32 and Practice Direction 32 govern the content and format of witness statements. A witness statement that contains inadmissible material, argument, or commentary on the law may be struck out in part or given reduced weight by the judge.

Common Mistakes to Avoid

Including irrelevant documents. Every document in the bundle should serve a purpose. Including 200 pages of emails when only 15 are relevant makes the judge’s task harder, not easier. Be selective. Quality over quantity.

Poor or inconsistent pagination. If your witness statement refers to “Bundle page 47” but the document is actually at page 52 because the numbering is wrong, the judge loses confidence in the bundle’s reliability. Check every page reference.

Missing documents. If your witness statement refers to a document that is not in the bundle, the judge cannot consider it. Cross-reference every document mentioned in every statement against the index.

Duplicates. Including the same document twice (or three times) wastes pages and causes confusion. Check for duplicates before finalising the bundle.

Illegible copies. Photocopies of photocopies, faded receipts, or tiny font sizes are unhelpful. If a document is difficult to read, provide the best available copy and consider a typed transcript alongside it.

Late filing. The court direction will specify when the bundle must be filed. Filing late may result in the trial being adjourned (at your cost) or the judge proceeding without proper preparation time. Treat the filing deadline as immovable.

No agreed bundle. The claimant should seek the defendant’s agreement on the bundle contents before filing. An agreed bundle avoids disputes at trial about what documents are before the court. Write to the other side, send a draft index, and ask for any additions or objections. Record this correspondence.

A Bundle Preparation Checklist

Use this checklist before filing your court evidence bundle:

• [ ] All statements of case included (claim form, particulars, defence, reply)
• [ ] All court orders included in chronological order
• [ ] All witness statements included and signed
• [ ] All documents referred to in witness statements are in the bundle
• [ ] Documents are in chronological order within each section
• [ ] Every page is numbered sequentially
• [ ] Index is complete with page numbers, dates, and descriptions
• [ ] Section dividers with tabs are in place (physical) or bookmarks set (electronic)
• [ ] No duplicate documents
• [ ] All copies are legible
• [ ] Bundle contents agreed with the other side (or objections noted)
• [ ] Sufficient copies prepared (court, each party, witnesses)
• [ ] Filed by the court’s deadline

Preparing for Trial

The evidence bundle is the foundation of your trial preparation. Once it is compiled, you should:

• Read every document in the bundle before the hearing
• Mark key passages that you intend to refer the judge to
• Prepare a chronology — a one or two-page timeline of key events with bundle page references
• Draft your submissions using bundle page references throughout

A judge who can follow your argument with precise page references will engage with your case far more effectively than one who is asked to search through unsorted papers.

For guidance on the directions questionnaire stage that precedes bundle preparation, or to explore the full range of litigation services available, the eLitigant service supports preparation at every stage of the court process.

Complex case? If your matter involves multiple documents, enforcement across courts, or multi-track allocation, see our Hybrid Assisted Drafting plan — 1,000 pages of barrister-grade drafting for £1,000.

Frequently Asked Questions

How many copies of the evidence bundle do I need? For a small claims hearing, bring three copies: one for the judge, one for each other party, and one for yourself. For fast track and multi-track trials, the court direction will specify the number of copies required. Typically, you need one for the judge (sometimes two if there is a bench of judges or a court Litigator), one for each party, and one for the witness box. Check the court’s directions carefully.

Can I add documents to the bundle after filing it? Additional documents can be included with the court’s permission, but late additions are discouraged. If you discover a relevant document after filing the bundle, prepare a supplementary bundle with its own pagination (continuing from the main bundle) and notify the other side and the court as soon as possible. The judge will decide whether to admit the document.

Do I need to include documents that are unhelpful to my case? If the case is on the fast track or multi-track and standard disclosure has been ordered, you have an obligation under CPR 31.6 to disclose documents that adversely affect your own case or support the other side’s case. These documents should be included in the bundle if they are relevant to the issues at trial. On the small claims track, there is no formal disclosure obligation, but withholding clearly relevant documents may undermine your credibility.

What is the difference between a trial bundle and a hearing bundle? The terms are often used interchangeably. Strictly, a “trial bundle” is prepared for the final trial, while a “hearing bundle” is prepared for an interim application (such as a summary judgment or striking out application). The format and principles are the same, but a hearing bundle is typically smaller and focused on the specific application before the court.

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Next in the series: Witness Statements: How to Draft Evidence the Court Will Rely On — the rules, format, and practical guidance for preparing your witness evidence.

This is Part 8 of 21 in the eLitigant Court Guide series. Visit our blog for the complete collection.