Trial Bundle: How to Prepare Court Bundles (2026 Guide)

In short: A trial bundle is the single, paginated, indexed and (where possible) agreed set of documents the court uses at trial — index and chronology, statements of case, orders, witness statements, expert reports, the contemporaneous documents you rely on, and authorities — prepared to Practice Direction 32 para 27 and Practice Direction 39A para 3, with electronic bundles now the default. eLitigant drafts the contents of your bundle, or checks the draft you have written, for £30 — you remain the litigant in person and file it yourself.

A trial bundle is the paginated, indexed, and agreed collection of documents the court will actually pick up at trial. It is not a filing cabinet. It is the working copy of your case — the judge’s bundle, the witness’s bundle, counsel’s bundle — and if it is wrong, the hearing suffers. Paragraph 27 of Practice Direction 32 and Practice Direction 39A set out what the court expects.

When Do You Need a Trial Bundle?

Whenever a matter is listed for trial, final hearing, or substantive hearing where evidence will be read. Directions order usually requires lodgement 7 clear days before trial (3 days for interim). Order wins over general rule.

Need bundles for: civil trials (County and High Court); High Court trials (KBD, ChD, Commercial, TCC); Family final hearings under FPR PD 27A; contested interim applications; appeals under PD 52B/52C.

What a Trial Bundle Involves

Single, paginated, indexed set of documents agreed (or claimant-compiled) for court use. PD 39A para 3. PD 32 para 27 on document presentation. Electronic bundles now default.

• Paginated consecutively
• Indexed — table at front listing every document and page
• Agreed where possible
• As short as reasonably possible — no duplicates, no irrelevance
• Bookmarked (e-bundles) — each document hyperlinked from index

The Rules That Apply

• CPR PD 32 para 27 — paginated, bound/ring binder, indexed, no duplicates (27.2). Witness statements under paras 17–25.
• CPR PD 39A para 3 — core bundle rule. Three copies for judge, witness, counsel.
• CE-File Guidance — single PDF, bookmarked, OCR-searchable, file-size limit 20–50MB.
• Chancery Guide 2024 ch.21
• Commercial Court Guide Appendix 10 — separate volumes for pleadings, statements, experts, core documents, authorities
• FPR PD 27A — strictest: preliminary documents by 11am working day before; 350-page limit without leave
• Appeal bundles: PD 52B and PD 52C

Standard Structure

1. Index and Chronology

First pages. Chronology: dated agreed events. Judges read chronology before anything else.

2. Statements of Case

Claim form, particulars, defence, reply, Part 20 claims, further info requests, in date order.

3. Orders

Every order in date order.

4. Witness Statements

Claimant’s first, then defendant’s, in order they will give evidence. PD 32 para 17+ compliant.

5. Expert Reports

After witness evidence. Joint statements (CPR 35.12) with reports.

6. Contemporaneous Documents

Disclosed documents actually relied on, strict chronological order. Usually largest section. Do not file everything disclosed; only what will be referred to.

7. Authorities

Often separate authorities bundle. Check directions order and court guide.

Electronic Bundles — 2026 Default

• Single PDF (or numbered volumes if over cap)
• OCR-searchable
• PDF bookmarks for every document
• Hyperlinks in index
• Internal pagination matching PDF pagination
• Lodged via CE-File
• Named clearly — [Case] – Trial Bundle – [Date].pdf

Who Prepares It

Claimant normally (PD 39A para 3.9). Parties cooperate. Standard practice: draft index 14–21 days before, defendant replies within 7 days, claimant produces agreed bundle + sends electronic copy, lodged by directions deadline.

Agreed bundle always preferred. If defendant refuses to agree: produce anyway and flag disagreement to court.

Key Deadlines

• Draft index exchanged: 21 days before trial (typical)
• Bundle agreed: 14 days before
• Bundle lodged with court: not more than 7 and not less than 3 clear days before trial (PD 39A para 3.3)
• Skeleton arguments: 2 clear days before trial (varies)
• Family (PD 27A): preliminary documents by 11am working day before

Common Mistakes

• Duplicates (PD 32 para 27.2 prohibits)
• No pagination (bundle rejected)
• Wrong order — chronological is not optional
• Over-long (1,200 pages for 2-day trial)
• No OCR (judge cannot find what they need)
• Missing bookmarks (e-bundle unusable)
• Last-minute additions
• Disagreeing over everything
• Ignoring court guide

How Chris Can Help

Preparing a bundle is mechanical but takes hours of indexing, pagination, OCR, bookmarking, cross-referencing. Chris does not file your bundle (you remain the litigant), but drafts everything that goes into it: index, chronology, skeleton argument, witness statements to PD 32 standard, list of issues.

Most self-represented litigants who land at eLitigant came the week before trial, panicking over a bundle. Speak to Chris first.

7-day money-back guarantee. We refund. We are miracle-makers, not miracle-workers. For complex trials with multiple witnesses and expert evidence: Draft my papers — £30 →.

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FAQ

How many copies?

PD 39A para 3.10: judge, witness, each party’s advocate, cross-examining advocate, witness box. Typical: 3–4 identical copies. E-bundles reduce this.

Every disclosed document?

No. Only what will be referred to at trial. Disclosure and trial bundle are different exercises.

Other side refuses to agree?

Produce anyway. Note disagreement. Include both sides’ views where applicable.

Add documents after lodging?

Supplementary bundle with continuing pagination. Late documents damage credibility.

Small claims track bundle?

Not always required, but most DJs expect one. Good practice even where not ordered.

Trial bundle vs hearing bundle?

Hearing bundle is broader. Trial bundle specifically for final trial — more extensive.

Page limit?

Family PD 27A: 350 pages without leave. Civil generally: “as short as reasonably possible” (PD 39A para 3.1). CoA: strict limits under PD 52C.

Judge wants paper but I prepared e-bundle?

Print from final PDF matching page-for-page. Bring 3 printed copies. Confirm with listing office when in doubt.

Frequently asked questions

How many copies of the trial bundle do I need?

PD 39A para 3.10 contemplates copies for the judge, the witness box, and each party’s advocate (and a cross-examining advocate), so typically three to four identical copies. Electronic bundles reduce the number of paper copies needed.

Do I include every disclosed document?

No. The trial bundle contains only the documents that will actually be referred to at trial. Disclosure and the trial bundle are different exercises — do not file everything that was disclosed.

When must the bundle be lodged with the court?

Under PD 39A para 3.3 the bundle is lodged not more than seven and not less than three clear days before the trial. Your directions order takes precedence over the general rule, so always check what your order requires.

What if the other side refuses to agree the bundle?

Produce the bundle anyway, note the disagreement, and include both sides’ views where applicable. An agreed bundle is always preferred, but you should not be held up if the other party will not cooperate.

Is there a page limit?

In family proceedings PD 27A sets a 350-page limit without the court’s leave. Civil bundles should generally be “as short as reasonably possible” (PD 39A para 3.1), and the Court of Appeal applies stricter limits under PD 52C.

Can I add documents after lodging the bundle?

Yes — by way of a supplementary bundle with continuing pagination. Late documents can damage your credibility, so keep additions to what is genuinely necessary.

Related guides: N265 list of documents (disclosure) · Witness statements · Skeleton arguments · All civil court forms