Preparation for trial - Preparation of trial bundles

Learning Outcomes

After reading this article, you will understand the rules and best practices for preparing trial bundles in civil litigation. You will be able to identify the required contents, explain the claimant’s responsibilities, and apply the relevant Civil Procedure Rules (CPR) and Practice Directions. You will also know how to organise, file, and serve trial bundles in compliance with SQE1 requirements.

SQE1 Syllabus

For SQE1, you are required to understand the procedural steps and legal requirements for preparing trial bundles in civil litigation. Focus your revision on:

  • the purpose and function of trial bundles in the trial process
  • the mandatory contents of a trial bundle under CPR and Practice Direction 39A
  • the claimant’s responsibility for preparation, filing, and service of the bundle
  • the required timing for filing and serving trial bundles
  • best practices for organisation, pagination, and agreement of bundle contents

Test Your Knowledge

Attempt these questions before reading this article. If you find some difficult or cannot remember the answers, remember to look more closely at that area during your revision.

  1. Who is responsible for preparing and filing the trial bundle in civil proceedings?
  2. What are the mandatory documents that must be included in a trial bundle under CPR Practice Direction 39A?
  3. By when must the trial bundle be filed and served before the start of trial?
  4. Why is it important to agree the contents of the trial bundle with the other party?

Introduction

Preparation of trial bundles is a key step in getting a civil case ready for trial. The trial bundle is a single, organised file containing all documents the court and parties will need during the hearing. The Civil Procedure Rules (CPR) and Practice Direction 39A set out strict requirements for the contents, format, and timing of trial bundles. Failing to comply can cause delays, wasted costs, or even sanctions. For SQE1, you must know what goes into a trial bundle, who prepares it, and how to ensure it is ready on time.

The Purpose of Trial Bundles

A trial bundle ensures that the judge, parties, and witnesses have easy access to all relevant documents during the hearing. It supports efficient case management, reduces delays, and helps the court follow the evidence and arguments. A well-prepared bundle avoids confusion and ensures the trial proceeds smoothly.

Key Term: trial bundle
A single, indexed, and paginated file containing all documents required for use at trial, prepared and filed in accordance with the CPR and Practice Directions.

The Claimant’s Responsibility

The claimant is responsible for preparing, filing, and serving the trial bundle unless the court orders otherwise. This includes:

  • collecting all required documents
  • agreeing the contents with the other party where possible
  • paginating and indexing the bundle
  • filing the bundle at court and serving copies on all parties and the judge

Key Term: filing
The act of submitting a document to the court so that it is placed on the official court file.

Key Term: serving
Delivering a document to the other party (or parties) in accordance with the CPR, ensuring they receive it in time for the hearing.

Mandatory Contents of the Trial Bundle

The required contents of a trial bundle are set out in Practice Direction 39A paragraph 3.5. The bundle must include:

  • the claim form and all statements of case (including particulars of claim, defence, reply, and any counterclaim)
  • a case summary and/or chronology of key events (if appropriate)
  • requests for further information and responses
  • all witness statements to be relied on at trial
  • any witness summaries
  • notices of intention to rely on hearsay evidence
  • notices of intention to rely on other evidence (e.g. plans, photographs)
  • all expert reports and responses
  • any orders giving directions for the conduct of the trial
  • any other documents necessary for the trial

Key Term: case summary
A concise document outlining the main issues, background, and key facts of the case, included in the trial bundle to assist the judge.

Key Term: chronology
A timeline of key events relevant to the dispute, included in the trial bundle to help the court understand the sequence of events.

Organisation and Format

The trial bundle must be:

  • indexed at the front, listing all documents and their page numbers
  • paginated consecutively throughout
  • divided into sections (e.g. statements of case, witness statements, expert reports)
  • filed in a ring binder or lever-arch file (or as an electronic bundle if required by the court)
  • prepared in enough copies for the judge, all parties, and witnesses

Key Term: pagination
The process of numbering each page in the trial bundle consecutively for easy reference during the trial.

Timing for Filing and Serving the Bundle

The trial bundle must be filed and served not more than seven days and not less than three days before the start of the trial, unless the court orders otherwise. Late filing can disrupt the hearing and may lead to sanctions.

Worked Example 1.1

A claimant is preparing for a fast-track trial listed for Monday 15th May. When must the trial bundle be filed and served?

Answer: The trial bundle must be filed and served no earlier than Monday 8th May and no later than Thursday 11th May.

Agreement of Bundle Contents

Where possible, the parties should agree the contents of the trial bundle in advance. This avoids disputes at trial and ensures all necessary documents are included. If agreement cannot be reached, the claimant should include a summary of the points of disagreement in the bundle.

Worked Example 1.2

The defendant objects to the inclusion of certain correspondence in the trial bundle. What should the claimant do?

Answer: The claimant should include a summary of the disagreement in the bundle and, if necessary, seek the court’s direction at the pre-trial review.

Best Practices and Common Pitfalls

  • Only include documents that are relevant and necessary for the trial. Avoid overloading the bundle with unnecessary material.
  • Ensure all documents are legible and complete.
  • Double-check pagination and indexing for accuracy.
  • Prepare electronic bundles in accordance with court requirements if directed.
  • File and serve the bundle on time to avoid disruption or sanctions.

Revision Tip

Prepare the trial bundle early and communicate with the other party to agree contents. Last-minute preparation increases the risk of errors and missed deadlines.

Exam Warning

Including irrelevant or excessive documents in the trial bundle can lead to criticism by the judge and may result in wasted costs orders.

Electronic Trial Bundles

Many courts now require or accept electronic trial bundles. These must be:

  • bookmarked for easy navigation
  • text-searchable
  • compliant with any specific court directions on format and security

Always check the court’s requirements for electronic bundles well in advance of the trial date.

Summary

A trial bundle is an organised, indexed, and paginated file containing all documents required for trial. The claimant prepares, files, and serves the bundle, ensuring it contains the mandatory documents listed in Practice Direction 39A. The bundle must be filed and served three to seven days before trial. Agreement of contents with the other party is best practice. Only include relevant documents, and follow any court directions for electronic bundles.

Key Point Checklist

This article has covered the following key knowledge points:

  • The trial bundle is a single, indexed, and paginated file containing all documents required for use at trial.
  • The claimant is responsible for preparing, filing, and serving the trial bundle unless the court orders otherwise.
  • The trial bundle must include the claim form, statements of case, case summary or chronology, witness statements, expert reports, and other mandatory documents.
  • The bundle must be filed and served not more than seven days and not less than three days before trial.
  • The parties should agree the contents of the bundle where possible, and only include relevant and necessary documents.
  • Electronic bundles must comply with court requirements for format, bookmarking, and security.

Key Terms and Concepts

  • trial bundle
  • filing
  • serving
  • case summary
  • chronology
  • pagination
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Pleased to share that I have successfully passed the SQE1 exam on 1st attempt. With SQE2 exempted, I’m now one step closer to getting enrolled as a Solicitor of England and Wales! Would like to thank my seniors, colleagues, mentors and friends for all the support during this grueling journey. This is one of the most difficult bar exams in the world to undertake, especially alongside a full time job! So happy to help out any aspirant who may be reading this message! I had prepared from the University of Law SQE Manuals and the AI powered MCQ bank from PastPaperHero.

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