Family Court Document Preparation
How to write a witness statement, build a court bundle, and prepare the documents that win cases. Step-by-step guidance for litigants in person.
Why Documents Matter
In family court proceedings, your documents tell your story. A well-prepared witness statement can be the single most important factor in determining the outcome of your case.
Judges in family court read hundreds of statements. They respond best to statements that are factual, chronological, focused on the children, and free from emotional language and personal attacks.
This guide covers the four most important documents you are likely to need: a witness statement, a position statement, a court bundle, and a skeleton argument.
How to Write a Witness Statement
Your witness statement is your main evidence document. It sets out your account of the facts and your position on the issues in the case.
Golden Rules
Write in the first person ('I did this...' not 'The applicant did this...')
Stick to facts — avoid opinions and emotional language
Use dates wherever possible
Number your paragraphs
Paginate the document
Keep it focused — include only what is relevant to the issues
Always end with the Statement of Truth
Recommended Structure
Heading
Your full name, case number, the court, and date. Title: 'Statement of [Your Name]'.
Introduction
A brief paragraph identifying who you are and your relationship to the child/case.
Background
A factual, chronological account of the relationship and current situation. Dates are important.
The Children
A section specifically about each child — their needs, routines, school, health, and relationship with each parent.
Your Position
Clearly state what order you are seeking and why it is in the children's best interests.
Concerns
If you have concerns about the other party, set them out factually, with dates and specific examples.
Statement of Truth
Sign and date the statement with the declaration: 'I believe that the facts stated in this witness statement are true.'
What is a Position Statement?
A position statement is a short document — usually 2 to 4 pages — that summarises your current position on the key issues and what you are asking the court to do.
Position statements are filed before interim hearings and dispute resolution appointments. They are not filed at the final hearing (where your witness statement carries the evidence).
Position Statement Structure
Name of the parties and case number
Brief background (2-3 paragraphs)
Issues in dispute
Your position on each issue
The order you are seeking
Any preliminary matters for the court
Building Your Court Bundle
A court bundle is an organised, paginated collection of all the documents in the case. Bundles are typically required for final hearings and sometimes for DRA hearings.
The bundle must be indexed and each document must be paginated continuously (page 1, 2, 3... throughout the entire bundle, not starting from 1 for each section).
Standard Bundle Sections
Section A: Court orders and directions
Section B: Applications and responses
Section C: Witness statements (in order — applicant first)
Section D: Expert reports (e.g. Cafcass Section 7)
Section E: Other documents (letters, records, etc.)
Our Bundle Builder tool automates this process — uploading, ordering, and paginating your documents for you.
Important Disclaimer
This guide provides general educational information only. It does not constitute legal advice. Court rules and practice directions change regularly. Always check the current rules or seek professional guidance.
