Trial bundles
When should the trial bundle be served:
The claimant must file the trial bundle not more than seven days and not less than three days before the start
of the trial.
What to include in the trial bundle:
By para 27.5 of PD 32 trial bundle should include a copy of:
(1) the claim form and all statements of case,
(2) a case summary and/or chronology where appropriate,
(3) requests for further information and responses to the requests,
(4) all witness statements to be relied on as evidence,
(5) any witness summaries,
(6) any notices of intention to rely on hearsay evidence under rule 33.2,
(7) any notices of intention to rely on evidence (such as a plan, photograph etc) under rule 33.6 which is not—
(a) contained in a witness statement, affidavit or expert’s report, (
b) being given orally at trial,
(c) hearsay evidence under rule 33.2,
(8) any medical reports and responses to them,
(9) any expert’s reports and responses to them,
(10) any order giving directions as to the conduct of the trial, and
(11) any other necessary documents.
Paragraph 27.12 of PD 32 provides that the contents of the trial bundle should be agreed where possible.
Where it is not possible to agree the contents of the bundle, a summary of the points on which the parties are
unable to agree should be included.
The bundle should state how long the estimated reading time it will take – if it is very long – a core bundle
should be made.
The case summary:
Each party should produce a case summary
The case summary should:
(a) concisely review the party’s submissions of fact in relation to each of the issues with reference to the
evidence;
(b) concisely set out the propositions of law advanced with reference to the main authorities relied on
(c) be divided into numbered paragraphs and paginated consecutively; and
(d) identify any key documents which the trial judge should, if possible, read before the trial starts.
When should the trial bundle be served:
The claimant must file the trial bundle not more than seven days and not less than three days before the start
of the trial.
What to include in the trial bundle:
By para 27.5 of PD 32 trial bundle should include a copy of:
(1) the claim form and all statements of case,
(2) a case summary and/or chronology where appropriate,
(3) requests for further information and responses to the requests,
(4) all witness statements to be relied on as evidence,
(5) any witness summaries,
(6) any notices of intention to rely on hearsay evidence under rule 33.2,
(7) any notices of intention to rely on evidence (such as a plan, photograph etc) under rule 33.6 which is not—
(a) contained in a witness statement, affidavit or expert’s report, (
b) being given orally at trial,
(c) hearsay evidence under rule 33.2,
(8) any medical reports and responses to them,
(9) any expert’s reports and responses to them,
(10) any order giving directions as to the conduct of the trial, and
(11) any other necessary documents.
Paragraph 27.12 of PD 32 provides that the contents of the trial bundle should be agreed where possible.
Where it is not possible to agree the contents of the bundle, a summary of the points on which the parties are
unable to agree should be included.
The bundle should state how long the estimated reading time it will take – if it is very long – a core bundle
should be made.
The case summary:
Each party should produce a case summary
The case summary should:
(a) concisely review the party’s submissions of fact in relation to each of the issues with reference to the
evidence;
(b) concisely set out the propositions of law advanced with reference to the main authorities relied on
(c) be divided into numbered paragraphs and paginated consecutively; and
(d) identify any key documents which the trial judge should, if possible, read before the trial starts.
