Family law guide
By Iblal Iqbal
Part of: Your First Family Court Hearing
A court bundle is the indexed file of documents a family judge reads before and during a hearing. In England and Wales, Practice Direction 27A (PD 27A) controls what goes in it, the order of its sections, its length and its filing deadline. A new version came into force on 2 March 2026. Since then the bundle is normally a PDF of up to 350 pages, called an e-bundle. Who prepares it depends on who started the case and who has lawyers. This guide explains each rule, what has to stay out and how to build the file so the judge can find your evidence. It is part of our guide to your first family court hearing.
Asked to prepare a bundle, or sent one with your evidence missing? You can book a free initial consultation with one of our specialists before the hearing.
Every bundle is one file, with an index and page numbers, holding only the documents the judge needs for a particular hearing. The judge reads it beforehand, and in court everyone works from the same page numbers.
PD 27A supplements Part 27 of the Family Procedure Rules. It applies to the first bundle in a case and to every later one (para 2.3). However, it does not apply to an urgent application if and to the extent that following it is impossible (para 2.4). Your own case directions also come first. A judge can vary most of these rules for a particular case, so read your latest order before you start (paras 2.2 and 4.1).
Paper is now the exception. Even so, the court can direct a paper copy for the judge, for a witness in the witness box or for a party without a lawyer who cannot open a PDF (para 4.3). A paper bundle fits in one A4 ring binder or lever arch file. It holds no more than 175 sheets and 350 sides (para 12.1).
The applicant prepares, files and serves it by default, at least five working days before the hearing. Where both sides have applied, the party whose application came first does it (paras 4.5 and 13.2).
If the applicant has no lawyer and the respondent has one, the respondent prepares the bundle instead (para 4.6). Where nobody has a lawyer and none of you can manage it, the court can exceptionally direct HM Courts and Tribunals Service to prepare it (para 4.7). In every other case, the contents should be agreed between you if possible (para 4.9).
Unless your order sets other dates, the parties must try to agree the contents seven working days before the hearing, and the short preliminary documents can follow the bundle by 11am on the working day before (para 13.2). If you have no lawyer, our guide for a litigant in person puts every date in one timetable. Once the court bundle is filed, nobody can change it before the hearing without the court’s agreement (para 13.3).
Every bundle opens with an index, then preliminary documents, then applications and orders, then statements and reports. Financial remedy cases follow Chapter 6 of PD 27A, and all other family cases follow Chapter 7.
| Section | Children and other family cases (Chapter 7) | Financial remedy (Chapter 6) |
|---|---|---|
| Preliminary documents | Case summary, statement of issues, position statements, any chronology and a reading list | Forms ES1 and ES2, chronology, position statements and a reading list, numbered separately |
| Applications and orders | Orders sealed, or marked as approved by the court | Same rule |
| Statements | Statements and affidavits, dated top right on the first page | Forms E, replies to questionnaires, then statements |
| Care plans | Where they apply, for example in care proceedings | Not listed |
| Reports | Expert and other reports, including the children’s guardian’s | Expert and other reports |
| Records | Medical records and police disclosure, where relevant | Not listed |
| Other documents | Divided into sections as needed | Same rule |
| Page numbers | Bates numbering: A1, A2, then B1 for the next section | 1, 2, 3 to the end, matching the PDF page numbers |
Within each section, documents run in date order from the front (paras 6.2 and 7.2). Statements and reports must be copies of originals that were signed and dated (paras 6.3 and 7.3). In care proceedings, a bundle for a case management hearing also holds the child’s birth certificate or an equivalent document. Our guide to Forms ES1 and ES2 explains the two summaries that open a financial bundle.
Leave out anything the judge does not need to read or that nobody will refer to at the hearing. PD 27A also bars whole classes of material, from texts and WhatsApp messages to bank statements and photographs, unless the court directs otherwise (para 5.2):
This surprises many parents, because the messages often feel like the heart of the case. The rule does let a specific document in where the judge needs to read it or someone will refer to it (para 5.2), but statements must not exhibit or duplicate the excluded material (paras 6.3 and 7.3). So if one message matters, describe it in your statement with its date. Then ask whoever prepares the bundle to include that message, or ask the court for a direction if they refuse. Our guide to witness statements in family court covers how to write about evidence like this.
An e-bundle can run to 350 A4 pages, and only the court can allow more (para 11.2). Individual documents also have their own caps, set out in Chapter 8 of PD 27A.
Position statements have limits of their own. In children cases and other non-financial cases, the cap is 3 pages unless the court accepts the case is complex (para 7.18). In financial remedy cases, the cap rises from 6 pages at the first appointment to 15 at the final hearing (para 6.12). Our position statement guide explains what to put in yours.
Case law goes in a separate authorities bundle of no more than ten cases (para 10.2). The court can also direct a shorter core bundle where a complete one is unnecessary (para 9.1).
The kind of case, the hearing and who holds the pen decide most of a bundle’s shape. Answer each question and the index below fills in line by line. Nothing you choose leaves this page.
Your bundle index
Choose the type of case to see which sections go in, in what order, and how the pages are numbered.
An unnumbered index comes first. Next come preliminary documents, applications and orders, statements, and expert or other reports. Medical records and police disclosure follow where relevant, then other documents. Pages carry Bates numbers, so the second section starts at B1 (paras 7.2 and 7.3).
An index comes first, then preliminary documents, applications and orders, and the evidence: Forms E, replies to questionnaires and statements. Expert reports and other documents follow. Pages run 1, 2, 3 and must match the PDF page numbers, while preliminary documents are numbered separately (paras 6.2, 6.3 and 6.5).
An unnumbered index, then preliminary documents, applications and orders, statements and care plans. Expert reports follow, including the children’s guardian’s, then medical records, police disclosure and other documents. Pages carry Bates numbers. For a case management hearing, add the child’s birth certificate (para 7.3).
Choose the case and the hearing to see the short documents that sit at the front.
A case summary of up to six pages if practicable and an agreed statement of the issues. Then each party’s position statement of no more than 3 pages, any skeleton argument, any Form FM5 and an agreed reading list (paras 7.10 and 7.18).
The same set, plus an agreed chronology and an agreed witness template. The template allows time for the judge to read and write the judgment, and normally none for evidence in chief, because witness statements stand as that evidence (para 7.10).
Form ES1 on the issues, a Form ES2 schedule of assets, an agreed chronology and an agreed reading list. Each party’s position statement is capped at 6 pages for a first appointment, 8 for other interim hearings and 12 for an FDR (paras 6.6 and 6.12).
Forms ES1 and ES2, an agreed chronology and reading list, and a position statement of up to 15 pages. A hearing listed for two hours or more also needs an agreed hearing template (paras 6.6 and 6.12).
A case summary and each party’s position statement, both on the standard template, with an agreed statement of the issues. Add any skeleton argument and an agreed reading list (paras 7.6 and 7.7).
The same set, plus an agreed chronology and an agreed witness template for the evidence. Where you disagree about these documents, each side’s version is set out at the right place (paras 7.6 and 7.7A).
Choose who is putting it together to see your part and the dates that matter.
Try to agree the contents seven working days before the hearing. Next, serve and file the bundle five working days before. The preliminary documents follow by 11am on the working day before (para 13.2).
The side with lawyers normally prepares, files and serves it (paras 4.5 and 4.6). Send them your statement and the documents you rely on early. When it arrives, make sure every page you need is there. You still write your own position statement.
In care proceedings the council is the applicant, so its legal team prepares, files and serves the bundle (para 4.5). Check that your statement and any assessment you rely on are in it. Your own position statement goes on the standard template (para 7.7).
By default the applicant prepares the court bundle. If the applicant has no lawyer and the respondent has one, the respondent does (paras 4.5 and 4.6). Settle it in writing now, because the seven working day point comes round quickly.
Choose the hearing to see what you still have to decide.
Which directions to ask for now, so the evidence you need for the final hearing is ordered in time. That turns on the facts of your case, which no index can weigh.
Which documents earn a place under the 350-page limit, and whether to ask the court to let in something PD 27A keeps out, such as messages or photographs.
This shows how PD 27A usually applies, not advice on your case. Your judge’s own directions come first.
Build one PDF, number every page by computer and bookmark every section and significant document. Run text recognition (OCR) on any scanned page of typed text, so the judge can search the bundle (para 11.2).
Upload the file to the HMCTS portal where one is available. Otherwise, email it to the court (para 14.2). The judiciary also publishes a step-by-step bundle guide for people without a lawyer, and PD 27A itself points to it (para 1.1).
Later hearings work differently by case type. In children and other non-financial cases, new documents go at the end of the right section, and superseded ones, such as an old case summary, come out (para 7.16). In a financial remedy case, by contrast, a fresh bundle is prepared for each hearing (para 6.10).
The court can take the case out of the list or put it further back, and it can make a costs order or a wasted costs order (para 3.1). A paper bundle filed in the wrong place can also be treated as never filed (para 15.1).
In practice, a judge with limited reading time may not reach a document buried in an overlong bundle, and cannot read a statement that never made it into the file. Both problems are far easier to fix at the agreement stage, seven working days out, than on the morning of the hearing.
We advised a father with no lawyer in a child arrangements case, where the mother's lawyers were preparing the bundle. It arrived five working days before the final hearing without his second statement or the school letter the judge had asked for. He had planned to hand in printed WhatsApp messages on the day. We explained what PD 27A keeps out and how to ask the other side, in writing, to add the missing documents. We also explained how to raise it with the court if they did not. With the court's agreement, a revised bundle with both documents was filed before the hearing. How a court deals with a late or incomplete bundle turns on the judge and the facts of each case.
Work to the agreement stage as your real deadline. Seven working days before the hearing, send the other side a written list of the documents you need in the bundle, with dates and page counts. If something is later left out, that list shows you asked in time, and the judge can see it.
Hannah Overton, Complex Children Specialist & Client Support
Only with the court's agreement. Once a bundle is filed for a hearing, it must not be amended before that hearing unless the court agrees. For example, it may agree where there is an accepted error or a need for a supplemental bundle (PD 27A, para 13.3).
Sometimes. Whoever filed the e-bundle must also provide a paper bundle where the court directs one. The same applies where there is a realistic chance of a witness giving evidence in person in the courtroom (PD 27A, para 4.3).
It is a system where each section of the bundle has a letter and its pages are numbered within it: A1, A2, then B1, B2 and so on (PD 27A, para 1.2). Children cases and other non-financial cases use it, so a new document can go at the end of a section without renumbering everything.
Only as far as it can. The practice direction does not apply to an urgent application if and to the extent that it is impossible to comply with it (PD 27A, para 2.4). Any directions the judge gives for that hearing still apply.
The person responsible for it must collect it straight away, or within 5 working days if that is not practicable. This applies unless the court keeps it or other arrangements are agreed. Bundles left uncollected can be destroyed without further notice (PD 27A, para 17.1).
Two problems with a court bundle cause the most trouble. The first is a bundle that arrives without your statement or the report you rely on, too close to the hearing to fix easily. The second is a file padded with messages and photographs that PD 27A keeps out, which uses up the judge's limited reading time.
A free initial consultation is a conversation with a specialist, who gives you initial advice tailored to your circumstances. It does not include drafting or reviewing documents. If you can, have your latest court order and the hearing date to hand when we speak.
Book a free initial consultation or call 0330 094 5880.
You can also read our guides to the position statement, witness statements and acting as a litigant in person. Or return to your first family court hearing.
General information about the law in England and Wales, not advice on your circumstances.
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