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Last reviewed: June 2026 · For use in England & Wales · eLitigant is a Community Interest Company (No. 16566612), not a law firm. Always check the current official form on GOV.UK before you file, and sign the statement of truth yourself.
Official form & guidance: Form N163 (Skeleton argument) →
What is Form N163?
Form N163 is the skeleton argument — a concise written summary of the legal arguments you will rely on at an appeal hearing in England & Wales. It is used by appellants and respondents alike under CPR Part 52 and Practice Direction 52A, and is normally filed alongside your Appellant’s Notice (N161 or N164) or within the time the court directs. A good skeleton defines the issues, sets out each ground in numbered paragraphs, and points the judge to the right pages of the bundle. eLitigant drafts your N163 skeleton argument from your grounds of appeal — concise, numbered and cross-referenced to PD52A standard. You check, sign and file. eLitigant CIC is a Community Interest Company, not a law firm: we provide drafting and information, not legal advice.
Who files an N163, and when?
Both sides in an appeal can file a skeleton argument:
- The appellant normally files the skeleton with the Appellant’s Notice (Form N161 for county court appeals, or N164 for small claims track appeals). If that is not practicable, it is usually filed shortly afterwards — commonly within 14 days under Practice Direction 52B. Always check the directions in your case.
- The respondent files a skeleton in answer, within the time set by the rules or the court’s directions, once permission to appeal has been dealt with.
- In the Court of Appeal, Practice Direction 52C sets the timetable and the skeleton should not normally exceed 25 pages. In other appeals, keep it proportionate to the issues.
Filing late, or not at all, can mean the court refuses to hear your argument or makes an adverse costs order — so treat the skeleton as essential, not optional.
What a skeleton argument must contain
Practice Direction 52A, paragraph 5, sets the standard. A skeleton argument must:
- be concise, and both define and confine the areas of controversy;
- be set out in numbered paragraphs;
- be cross-referenced to any relevant document in the appeal bundle (for example, “judgment, bundle p.42”);
- be self-contained — it must not incorporate by reference material from another document;
- not include extensive quotations from documents or authorities; and
- cite an authority only where it is necessary, stating the proposition of law the authority establishes and the parts relied on.
The aim is to help the judge grasp your case before the hearing — not to re-argue every fact. A judge who can follow your skeleton in ten minutes is a judge ready to hear you.
How to structure your N163
A clear, conventional structure works best:
- Heading — the court, the claim/appeal number, the parties, and “Skeleton argument on behalf of the Appellant / Respondent”.
- Introduction — what is being appealed, the order made below, and the order you ask the appeal court to make.
- The issues — a short, numbered list of the questions the court must decide.
- Essential facts / chronology — brief, neutral, cross-referenced to the bundle.
- The grounds — each ground in turn: the error said to have been made (of law, principle or procedure), the proposition relied on, and any authority.
- The order sought — precisely what you want, and any consequential directions.
- Time estimate, name, signature and date.
Common mistakes to avoid
- Writing a long narrative that re-argues the facts, instead of identifying where the lower court went wrong.
- Dumping authorities or long quotations — this breaches PD52A and irritates the court.
- Forgetting numbered paragraphs or bundle cross-references.
- Going over the page limit, or filing after the deadline.
- Confusing the documents: the N163 skeleton is separate from the Appellant’s Notice (N161 / N164) and from the Respondent’s Notice (N162).
How eLitigant drafts it for you
Tell Chris the decision you are appealing and your grounds. Chris drafts a skeleton argument that is concise, numbered, cross-referenced and structured to PD52A — ready for you to check against your bundle, personalise, sign and file. Draft your Appellant’s Notice and skeleton together if you need to.
Get your N163 skeleton drafted →
eLitigant drafts it; you check, sign & file. Not a law firm; information, not advice.
See it done — what Chris drafts for you
A worked skeleton argument, drafted to PD52A standard from your grounds — ready for you to check against your bundle, personalise and file. Fictional sample.
IN THE COUNTY COURT AT BIRMINGHAM
On appeal from District Judge Avery · Claim No. K9QZ1234
BETWEEN: Daniel Okafor (Appellant) — and — Brightline Motors Ltd (Respondent)
SKELETON ARGUMENT ON BEHALF OF THE APPELLANT
1. Introduction
1.1 This is the Appellant’s skeleton argument in support of his appeal against the order of DJ Avery dated 2 May 2026 dismissing his claim for £1,860. The Appellant seeks an order setting the judgment aside and entering judgment in his favour [bundle p.3].
2. The issue
2.1 Whether the judge erred in law in finding that the vehicle was of satisfactory quality, when the agreed facts showed a gearbox fault present within 30 days of delivery.
3. Grounds
3.1 Ground 1. The judge failed to apply the short-term right to reject under section 22 of the Consumer Rights Act 2015. The fault arose on 19 April 2026, 16 days after delivery [witness statement, bundle p.18].
3.2 Ground 2. The judge made no finding on the independent engineer’s report [bundle p.27], which was unchallenged.
4. The order sought
4.1 That the appeal be allowed, the judgment set aside, and judgment entered for the Appellant in the sum of £1,860 with interest and costs.
Fictional sample for illustration. All names, figures and facts are invented.
Form content and official guidance on this page are reproduced or adapted from material published by HM Courts & Tribunals Service on GOV.UK. Contains public sector information licensed under the Open Government Licence v3.0. eLitigant CIC is independent and is not affiliated with, or endorsed by, HM Courts & Tribunals Service or any government department. Always check the current official form on GOV.UK before you file.
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