How to Prepare a Court Bundle for a Child Arrangements Order Hearing

What a Court Bundle Is and Why It Matters

A court bundle is the organised set of documents that the judge reads before and during your hearing. In child arrangements proceedings, the judge typically receives the bundle several days in advance. If your bundle is missing key documents, disorganised, or filed late, the court may adjourn or relist the hearing and may make an adverse costs or wasted costs order.

Practice Direction 27A of the Family Procedure Rules governs bundles for hearings in the family court, including when you represent yourself. Follow any case-specific directions from the court.

When You Need a Court Bundle

Not every hearing requires a full bundle:

• FHDRA (First Hearing Dispute Resolution Appointment): Practice Direction 27A applies. The court may direct a core bundle if a complete bundle is unnecessary; follow its directions about the documents to include.
• Dispute Resolution Appointment (DRA): Prepare a bundle with the documents relevant to the hearing, subject to the court's directions.
• Final Hearing: A bundle is required, but the court may direct a core bundle instead of a complete bundle. The judge will have directed who is responsible for preparing it.

If the court has not given specific directions about the bundle, ask the court office or check your latest court order — it will usually say who must file the bundle and by when.

What Goes in the Bundle

The contents should follow Practice Direction 27A's standard structure. The bundle begins with an unpaginated index, followed by these sections for a child arrangements case:

Section A — Preliminary documents

• An up-to-date case summary, limited to six pages if practicable
• A statement of the issues to be decided
• Position statements and any skeleton arguments
• An up-to-date chronology for a final hearing, or if the case summary is insufficient
• A list of essential reading and, for an evidential, contested, or final hearing, a hearing timetable

Section B — Applications and orders

• Form C100 (your original application)
• Form C1A (if allegations of harm were made)
• Court orders made in the proceedings, in date order

Section C — Statements and affidavits

• Witness statements, in date order, without duplicating documents referred to in them

Section D — Care plans

• The care plan, if applicable

Section E — Expert and other reports

• Cafcass safeguarding letter or Child Impact Report
• Section 7 welfare report (if ordered)
• Any expert reports (e.g., drug testing results, psychological assessments)
• Other reports, including those of a children's guardian

Section F — Relevant medical records

• Medical records relevant to the hearing

Section G — Relevant police disclosure

• Police disclosure relevant to the hearing

Section H — Other relevant documents

• Documents the court needs to read or that will be referred to at the hearing, divided into sections as appropriate. Include correspondence only where the court directs it or it is necessary for the hearing.

How to Organise It

Page numbering: Use Bates numbering by section (for example, A1, A2, then B1, B2). The judge refers to documents by their bundle page number, so consistent numbering is essential.

Tabs or dividers: Use labelled tabs to separate sections. If you are filing a paper bundle, use a ring binder or lever arch file — loose papers or stapled bundles are difficult for the judge to navigate during a hearing.

No duplicates: Include each document once only. If the same letter appears in both a witness statement exhibit and the correspondence section, include it in one place and cross-reference it in the other.

E-bundles: Unless the court directs otherwise, bundles should be electronic PDFs. Use computer-generated Bates numbering, link the index entries to the documents, bookmark each section and significant document, and make the PDF searchable where possible. The court's directions control the format.

Filing Deadlines

Practice Direction 27A requires the bundle, apart from preliminary documents that are not yet available, to be filed and served no later than 5 working days before the hearing. Any preliminary documents not already filed and served are due by 11am on the working day before the hearing. Parties should seek to agree the bundle's contents 7 working days before the hearing. Case-specific directions may set a different timetable — always check.

If you miss the deadline, contact the court office immediately. A late bundle may be accepted with the judge's permission, but arriving at a hearing without a bundle risks adjournment.

Position Statements

The bundle normally includes a position statement from each party — a short document (2–3 pages maximum) that tells the judge:

• Your current position on the arrangements
• What has changed since the last hearing
• What order you are asking the court to make
• Any issues you want the court to address

Position statements are preliminary documents and should be filed and served by 11am on the working day before the hearing, unless the court gives a different direction. They should not exceed 3 pages unless the court directs a different limit. Write in plain language, stick to facts, and avoid attacking the other party personally. The judge is assessing the child's welfare, not scoring points between adults.

Practical Tips for Litigants in Person

If you have never prepared a court bundle before:

• Start early — gathering documents, numbering pages, and creating the index takes longer than you expect
• Make sure each party has access — the bundle must be filed with the court and served on the other parties in the format directed
• Check with the court — phone the family court office to confirm whether they want paper or electronic bundles, and whether they have a preferred format
• Keep originals safe — file copies in the bundle, not your only originals of important documents

The Child Arrangements Order Process Guide includes a hearing preparation checklist and a paperwork tracker that walks through what you need for each stage of the court process — from the initial C100 through to final hearing bundles.

See more England and Wales guides →