The trial bundle checklist courts actually apply.

Heads-up: many older checklists still cite “Practice Direction 39A”. That direction was removed in its entirety by the 104th Update; the bundling provisions now live in Practice Direction 32 (Evidence), section 27 — Agreed bundles for hearings. Same substance, new home. If a guide cites PD 39A, it is out of date.

Who files, and by when

CPR rule 39.5: unless the court orders otherwise, the claimant files the trial bundle. Timing: not more than 7 days and not less than 3 days before the trial starts (rule 39.5(2); PD 32 §27.4).

If the claimant is unrepresented, the court may direct another party to prepare it (PD 32 §27.7) — but do not assume that will happen; agree who is preparing it early.

What goes in the bundle

PD 32 §27.5 lists the default contents:

• 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 to be relied on;
• any witness summaries;
• notices of intention to rely on hearsay evidence;
• notices of intention to rely on other evidence (plans, photographs, etc.);
• medical reports and responses to them;
• experts’ reports and responses to them;
• any order giving directions about the trial;
• any other necessary documents.

The parties should try to agree the contents before filing (PD 32 §27.1). Bundles agreed for a hearing make their contents admissible as evidence of their contents unless the court orders otherwise or a party objects in writing (§27.2).

Presentation requirements

• Paginated continuously throughout — one running page number, not per-section (§27.8).
• Indexed, with a description of each document and its page number (§27.8).
• More than 100 pages → numbered dividers between groups of documents (§27.8).
• Ring binder or lever arch file; multiple bundles clearly distinguishable; if there are many, prepare a core bundle cross-referenced to the rest (§27.9).
• Experts’ reports may sit in a separate bundle, cross-referenced (§27.10).

A checklist you can run today

1. Collect every document above into one inventory with dates.
2. Agree the contents with the other side in writing.
3. Order documents: statements of case → orders → witness statements → experts → chronologically-ordered exhibits relied on.
4. Paginate continuously; number the index with descriptions and page numbers.
5. Add dividers past 100 pages; build a core bundle if the file is huge.
6. File with the court 3–7 days before trial; serve the other parties.
7. Bring the originals of bundled documents to trial (§27.6).

How EvidenceCanvas helps

The bundle is an organisation problem: the right documents, in order, numbered, indexed. EvidenceCanvas keeps the inventory, timeline and release-checked exports so the bundle comes together from materials you already control — and the export carries the pagination your index needs. See the Form E walkthrough for the family-court version of the same discipline.

Sources verified 5 October 2026: CPR rule 39.5 (legislation.gov.uk, SI 1998/3132); PD 32 §27 “Agreed bundles for hearings” (justice.gov.uk); 104th CPR Update (PD 39A removed). Not legal advice.