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.
① Draft it from scratch
Bring your facts and the order listing the hearing — Chris drafts your skeleton with numbered paragraphs, pinpoint citations and a clean issue structure, tuned for E&W civil procedure.
② Check the draft you’ve written
Already written a skeleton? Upload it and Chris reviews the structure, citations, bundle references and relief sought against a professional standard.
③ You’ve been served — respond
Received an opponent’s skeleton or an order listing a hearing? Run it by Chris and get a focused response drafted to elite drafting standards.
A skeleton argument is the single most important document you will submit before a hearing. It is the written distillation of your case — the issues, the facts that matter, the law that governs, and the relief you ask the court to grant. Judges read it before you ever stand up. If it is clear, numbered, and properly cited, you have already won half the battle of being understood. If it is rambling, argumentative, or uncited, you start the hearing on the back foot. Build your case with Chris. Make your claim. Win your day.
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What Is a Skeleton Argument?
A skeleton is a short, numbered written document that sets out the party’s position in advance of a hearing. It is not a pleading, not a witness statement, not evidence. It is your roadmap — and in self-representation, your roadmap — to how the argument will run on the day. The court uses it to pre-load the case, identify the issues in dispute, and locate the authorities you rely on before the hearing begins. A well-drafted skeleton does three things at once: tells the judge what the dispute is really about, tells the judge what the law says, and tells the judge exactly what order you want.
When Is a Skeleton Required?
- Appeals (CPR 52) — required for virtually every appeal. PD 52A, 52B, 52C set filing windows.
- Trials in the County Court and High Court — expected in multi-track matters and most fast-track trials turning on law.
- Contested applications — anything likely to last over 30 minutes or raising a point of law.
- CMCs on complex cases — increasingly expected in Chancery, Commercial, and TCC.
- Family proceedings — FPR Practice Directions expect skeletons for appeals and contested final hearings.
- Tribunal hearings — ET, EAT, Tax Tribunal, Upper Tribunal routinely expect them.
Check the order listing the hearing and the relevant Practice Direction. The rules are your shield.
The Structure Judges Expect
- Heading block — court, claim number, parties, hearing date.
- Introduction — who you are, what the hearing is, what order you seek.
- The Issues — numbered list of the questions the court must decide.
- The Facts — short neutral chronology cross-referenced to the bundle.
- The Law — statutory provisions, rules, and authorities.
- Submissions — argument, issue by issue.
- Relief Sought — precise order you ask the court to make.
- List of Authorities — appendix.
Every paragraph numbered. Every page numbered. Date it. Judges read dozens a week — conformity is persuasive.
How to Write Each Section — Step by Step
1. The Heading Block
Mirror exactly the heading on the claim form or appellant’s notice. Get the claim number right. The court clerk should match it to the file in five seconds.
2. Introduction
Two paragraphs maximum. Who, what, why. Do not begin with argument or facts. Tell the judge where you are taking them.
3. The Issues
Three or four clean questions is normal. Ten is too many — you have not thought hard enough. Sharp issues; everything downstream writes itself.
4. The Facts
Neutral, numbered, cross-referenced. Use [B/3/45] format. Do not argue in the facts section. Save argument for submissions.
5. The Law
Statute first, rule, leading cases. Quote exact wording. Cite pinpoint paragraphs: Smith v Jones [2019] EWCA Civ 123 at [42].
6. Submissions
Take each issue in turn. State the issue, the test, apply the test to the facts, conclude. Short paragraphs, one point each.
7. Relief Sought
The precise order you want. Copy the words as they would appear in a draft order. Leave nothing for the judge to translate.
8. List of Authorities
Appended. Full citation, alphabetical, neutral citation where available.
Citing Authority Properly
- Neutral citation. Mitchell v News Group [2013] EWCA Civ 1537.
- Pinpoint. Never cite a whole case. Always at [15]-[18].
- CPR references. CPR 3.9.
- Statutes. Limitation Act 1980, s.5.
- Link to BAILII for electronic filings.
- Rule of three. Three strong on-point authorities beat ten weak ones.
If a case cuts against you, cite it and distinguish it. The court will find it anyway. Your credibility is worth more than the point you are trying to dodge.
Length, Style, Formatting
- Trial skeletons: 10–15 pages. Complex commercial up to 25.
- Appeal skeletons: Court of Appeal 25 max (PD 52C). High Court 10–15.
- Application skeletons: 5–10 pages.
- Font: 12-point Times New Roman. 1.5 spacing. Numbered throughout.
- Margins: 2.5cm. Judges annotate.
- Headings: bold, numbered, consistent hierarchy.
Common Failings
- Too long. Over 20 pages for a routine trial — cut it.
- Too argumentative in the wrong places. Facts section for facts. Save argument for submissions.
- No pinpoint citations. Citing Mitchell without paragraph number tells the court you have not read it.
- Copy-pasting from pleadings. Particulars assert; skeleton argues. Different jobs.
- Unnumbered paragraphs. Non-negotiable.
- No bundle references. Every factual assertion needs evidence location.
- Missing the relief. The judge should never have to ask what order you want.
- Submitted late. Late skeletons risk refused permission to rely.
- Personal attacks. Never. Court-deferential tone at all times.
Prepare to win, plan not to fail.
The Rules That Apply
- CPR 52 PDs — appeals. Appellant 14 days before, respondent 7 days before.
- CPR 29 — multi-track trial preparation.
- CPR 23 — applications.
- Specialist Court Guides — Chancery, Commercial, TCC, Admiralty.
- FPR PD 27A — family bundles and skeleton requirements.
- ET Rules 2024 — skeletons expected for final hearings.
Missing the skeleton deadline is a relief-from-sanctions problem under CPR 3.9 — a problem you do not want.
How Chris Can Help
Chris drafts skeleton arguments to a professional standard — numbered paragraphs, pinpoint citations, clean issue structure, precise relief. You bring the facts, the order listing the hearing, and whatever documents you already have. Chris turns them into a skeleton you can file.
Don’t know exactly which form or document you need? That is fine — just tell Chris what you are trying to achieve. Upload any documents, describe your situation, tell Chris what you need drafted. Chris produces the correct document in the correct format — skeleton argument, witness statement, particulars of claim, Part 36 offer, settlement agreement — whatever your case requires. Start free with Chris → Express Document.
7-day money-back guarantee. Not happy with the draft before you sign and send? We refund. We are miracle-makers, not miracle-workers — if the underlying merits are weak, no drafting saves a bad case. Chris makes strong cases stronger.
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Frequently Asked Questions
Do I have to file a skeleton if I’m a litigant in person?
Yes, if the rules or the order require one. The court holds LiPs to the same procedural standards as represented parties, though judges read with a little more patience.
How long should my skeleton be?
County Court trial 10–15 pages. Court of Appeal up to 25 (PD 52C). Interim application 5–10 pages.
When do I have to file it?
Check the order and relevant PD. Typical appeal windows: 14 days before for appellant, 7 days before for respondent.
Can I just copy my particulars into a skeleton?
No. Particulars assert facts; skeleton argues law applied to facts. Different documents, different jobs.
Do I need to cite cases?
Yes where law is in issue. Cite statute, rule, leading case with pinpoint paragraph references.
What if the other side’s skeleton is longer?
Length is not persuasiveness. A tight 10-page skeleton routinely beats a 40-page ramble.
Can Chris draft my skeleton?
Yes. Every section drafted to CPR standard.
What if I need qualified reviewer sign-off?
Chris drafts to a high, professional standard; you review every document before you file.