Court bundle requirements in England and Wales

Where the rules are

Bundle requirements are spread over a rule, a practice direction, judicial guidance and the court guides. Their old home, paragraph 3 of Practice Direction 39A, no longer exists: the 104th Practice Direction Update omitted PD 39A with effect from 6 April 2019 and inserted the trial bundle provisions into Practice Direction 32.

The general guidance says itself that it yields to court-specific guidance and to directions in the individual case. The Chancery Guide and other court guides have bundle chapters of their own, and family proceedings follow their own practice direction, FPR PD 27A.

What goes into a trial bundle

Unless the court orders otherwise, PD 32 para 27.5 says the trial bundle should include copies of:

• the claim form and all statements of case;
• a case summary and/or chronology where appropriate;
• requests for further information and the responses;
• all witness statements relied on as evidence, and any witness summaries;
• notices of intention to rely on hearsay evidence, or on evidence such as plans and photographs not contained in a witness statement, affidavit or expert’s report;
• medical reports and experts’ reports, with the responses to them;
• any order giving directions for the conduct of the trial;
• any other necessary documents.

The claimant’s legal representative with conduct of the claim is responsible for the bundle, even if the work is delegated (para 27.7). The parties should agree the contents where possible and summarise what they cannot agree (para 27.12); identical bundles go to every party and for the witnesses (para 27.13).

Pagination, index and order

• Pagination and index. Paginated continuously throughout and indexed with a description of each document and its page number (para 27.8).
• Dividers. Over 100 pages, numbered dividers between groups of documents (para 27.8).
• Several bundles. Clearly distinguishable, for example by colour or letter; with numerous bundles, a core bundle of the documents essential to the proceedings, with references to the supplementary bundles (para 27.9).
• Experts. Experts’ reports may go into a separate bundle, cross-referenced in the main one (para 27.10).
• Illegible documents. A typed copy next to the original, cross-referenced (para 27.11).
• Order. Contemporaneous documents relied on by either party form a single run in chronological order of creation (para 27.14).
• Paper. Copied double-sided (para 27.15).

PD 32 still speaks of ring binders and lever arch files (para 27.9). The format of electronic bundles comes from the general guidance and, in the Commercial Court, from Appendix 7 of its Guide.

Electronic bundles: the general guidance

The General Guidance on Electronic Court Bundles of 29 November 2021 sets ten requirements:

1. PDF format.
2. Computer-generated page numbers, starting at 1 on the first page (index included) and running to the last, so that the pagination matches the PDF numbering; a paper copy has the same pagination.
3. Every index entry hyperlinked to its document; all significant documents and sections bookmarked with a short description and the page number.
4. OCR on every page with typed text that was not created electronically.
5. Landscape pages shown in landscape, readable from left to right; no page upside down.
6. Default view 100 %.
7. A core bundle, if required, in PDF and meeting the same requirements as a paper one.
8. Usually a single hearing bundle and a separate authorities bundle, rather than many bundles.
9. No more than 300 dpi, and a file size no larger than necessary.
10. Pages added after the bundle reached the judge go at the end, paginated accordingly; the judge receives the new section and, separately, the revised bundle.

The file name should contain the case reference, a short case name and the bundle’s content. E-mails to justice.gov.uk addresses may carry no more than 36Mb in aggregate; larger bundles go by the route the court directs, such as the Document Upload Centre.

Commercial Court: Section J.4 and Appendix 7

In the Commercial Court only electronic bundles are filed unless the judge asks for paper (Appendix 7 para 1; J.2.1). Appendix 7 adds detail to the general guidance:

• A core bundle for every trial, and for heavy applications where useful, separately paginated, with each page also showing its main bundle and page reference (para 3).
• Only the documents necessary for the hearing (para 5), and no more than one copy of any document (para 7(vii)).
• File names with the claim number, a short case name and the bundle’s number or letter (para 7(iii)).
• Bookmarks with page numbers; indexes, searchable if possible; and a separate index to all the hearing bundles, hyperlinked if possible (para 7(iv)–(vi)).
• Contemporaneous documents and correspondence in chronological order; a central contract may sit elsewhere, with a page in the chronological run saying where (para 7(viii)–(ix)).
• Page numbers in the bottom right-hand corner, distinguishable from other numbering, starting afresh in each bundle, matching the PDF pages and, where possible, preceded by the bundle’s letter or number (para 7(x)–(xi)).
• OCR; landscape originals turned 90 degrees clockwise; 100 % view; personal data and metadata removed; scans no more than 300 dpi; transcriptions and translations placed next to the original (para 8).

Bundle C (CL-2026-000123, Alpha v Beta).pdf
Stamp, bottom right:  C1 … C412
PDF page 245  =  stamp C245
Bookmark:  Board minutes, 12 March 2019 – C245

Timetable for trial bundles

Each step applies unless the court orders otherwise; “start of the trial” is defined in J.3.

Page and size limits

PD 32 sets no page limit for a civil trial bundle; the Commercial Court relies on selection instead. Limits do apply elsewhere:

Checklist before you send the bundle

1. Contents checked against PD 32 para 27.5 and the order for directions.
2. Index lists each document with a description and page number, and every entry is hyperlinked.
3. Pagination is computer-generated, continuous and matches the PDF page numbers.
4. Every significant document and section is bookmarked.
5. Contemporaneous documents form one chronological run, without duplicates.
6. OCR applied; illegible documents transcribed; translations next to the originals.
7. Metadata and personal data removed.
8. File name carries the case number, a short name and the bundle letter or content.
9. Size fits the delivery route the court has set; otherwise use the alternative it names, such as a secure download link.

For the hyperlinked skeleton or submission that refers to the bundle, see our guide to hyperlinked e-briefs.