Build an evidence bundle the tribunal can use

Read the latest directions from beginning to end before assembling anything. Record who must prepare the bundle, what must be exchanged first, the permitted format and size, the deadline, the number of paper copies if any, and everyone who must receive it. The directions in your case take priority over this general guide.

A hearing bundle usually brings together evidence and case documents that have already been exchanged in accordance with the directions. Do not use the bundle deadline as a chance to introduce new evidence. The tribunal may disregard or exclude evidence produced late or contrary to a direction.

• Latest directions and every later variation
• Person responsible for the bundle
• Documents each party must provide
• Date for agreeing the index or contents
• Bundle format, file-size or naming requirement
• Pagination or section-numbering requirement
• Filing and service deadline
• Tribunal and party recipients
• Number of paper copies, if required
• Proof of filing and service

Put a one-page index first. Record each section, document description, date and start–end bundle pages. Then arrange the case so the panel moves from the tribunal's instructions, to the live disputes, to the documents needed to decide them. Use a clean divider page for each main section and count every divider in the pagination.

The exact order in your directions wins. If no order is prescribed, the sequence below is a practical service-charge pattern: orders first, the disputed-items schedule near the front, financial records separated by charge year, and supporting reports, correspondence, photographs, quotations and consultation material in distinct sections.

• Front sheet: case reference, property, parties, hearing date and bundle version
• One-page index: section, document, date and start–end pages
• Current directions followed by later notices, variations and orders in date order
• Application form, statement of case, response and any permitted reply
• Relevant lease, variations, plan and apportionment provisions
• Current schedule of items in dispute / Scott schedule
• Service-charge demands, budgets, accounts, statements and payment records
• Invoices, contracts, specifications and proof of expenditure, separated by charge year or issue
• Reports and other technical material
• Relevant correspondence, trimmed to the messages that prove a live point
• Labelled colour photographs and plans
• Alternative quotations or estimates
• Section 20 consultation notices and observations
• Signed witness statements and clearly identified exhibits
• Permitted expert reports and any joint statement
• Costs material, written submissions or authorities only where directed or permitted

Keep the original files outside the working PDF. Give each source a short neutral name, record its date and issue ID, and place a copy in the intended bundle section. Assemble the final bundle only after the section order is stable. This is safer than repeatedly editing a large merged PDF and makes a missing, duplicated or superseded document easier to spot.

Use the evidence-to-page map before and after merging. Before merging, it records what the document is meant to prove and where it will sit. After final pagination, complete the start and end page columns and update every reference in the disputed-items schedule, statements and hearing note. Preserve the exact final PDF separately from the source folder.

• One working copy of each source document
• Neutral source name and document date
• Issue ID and fact the document is meant to prove
• Proposed bundle section
• Superseded and duplicate versions marked before assembly
• Final start and end pages recorded after merging
• Schedule, statements and hearing notes updated to final page numbers
• Exact served PDF preserved without later edits

Take the disputed-items schedule row by row. For each legal or factual proposition, identify the document and exact bundle page range that supports it. If the point depends on a witness, make sure the witness statement explains what that person observed and identifies the exhibit. If no evidence supports a point, the gap is visible while there is still time to address it properly.

Separate invoices and accounts by service-charge year when several accounting periods are disputed. Within a year, order the documents by schedule row or chronology. Use a short chronology for events across several documents. Include relevant correspondence only; a large email chain with repeated signatures and quoted messages makes the decisive passage harder to find.

• Issue ID and disputed charge
• Question the tribunal must answer
• Lease clause or legal test
• Fact that must be proved
• Witness statement paragraph
• Supporting document and start–end bundle pages
• Other party's evidence and response
• Amount or calculation affected
• Remaining evidential gap

Witness statements should be in the witness's own words, separate personal knowledge from information learned from documents or other people, and refer to exhibits by a stable label. Sign and date the version required by the directions. Do not rely on a photograph, spreadsheet or invoice without explaining what it is and why it proves the point.

For photographs, retain the original and state who took the image, when, where, what direction it faces and what feature it is intended to show. Provide colour copies unless the tribunal permits otherwise. For spreadsheets, show the inputs and calculation method in a readable schedule rather than supplying an unexplained total.

Expert evidence requires the tribunal's permission. Do not commission a report and assume it can be added later. Follow any direction limiting the questions, requiring a joint expert or setting the report format and service date.

• Witness name, role and source of knowledge
• Numbered paragraphs and referenced exhibits
• Signed and dated statement
• Exhibit cover or stable exhibit label
• Photograph date, author, location and description
• Readable calculation with source figures
• Expert permission and permitted questions
• Legible colour copies of plans and photographs

Number every page in one sequence, including the index and divider pages, unless the directions require A and R numbering or another system. The index start–end range must match the numbers displayed on the document. Do not rely on a document's original page number. Check that every page is upright, complete and readable and that no document has been silently cropped.

For an electronic bundle, use one PDF unless the directions say otherwise. Make text searchable where reasonably possible and add PDF bookmarks for every main divider and important document. Clear dividers, continuous pagination and bookmarks make a long electronic bundle materially easier to use. Use a clear filename containing the case reference and version date. Do not password-protect the filed copy unless directed. Compress images only if dates, figures and detail remain legible.

For a paper bundle, use clear dividers and a ring binder or lever arch file. Current HMCTS guidance says a single paper bundle should not exceed 350 pages; use clearly labelled volumes if more are necessary. Each paper copy must use the same pagination as the filed version.

• Index tested against every start and end page
• Continuous, visible pagination
• Divider pages included in the page count
• Pages upright and in the intended order
• No unintended duplicate, blank or missing pages
• Text, figures and photographs legible
• Searchable text and PDF bookmarks
• Clear case-reference and version filename
• Matching electronic and paper pagination
• Volume and page range marked on each cover

Send the proposed index or draft bundle to the other party at the stage required by the directions. The tribunal expects the parties to try to agree the bundle even though they dispute the case. Agreeing that a document is included does not necessarily mean agreeing what it proves.

If the contents cannot be agreed, follow the directions. Current HMCTS guidance says each party may need a separately numbered bundle using A for applicant and R for respondent. Do not omit the other side's relevant document simply because it is unhelpful; record the disagreement and ask the tribunal for a direction if necessary.

File and serve the exact same version on every required recipient. Keep the covering letter or email, attachment list, delivery record and final file checksum or saved copy. If something must be corrected after filing, notify everyone and seek permission or a direction instead of circulating an unmarked replacement.

• Proposed contents sent in time
• Disagreements recorded neutrally
• Final version label and date
• Identical file sent to tribunal and every party
• Case reference in covering message
• Attachment list checked
• Delivery or filing confirmation saved
• Correction or supplementary bundle authorised and clearly labelled

Remove duplicate documents, irrelevant correspondence, private data that has no bearing on the issues, personal annotations and superseded working drafts. Do not place mediation communications, without-prejudice settlement material or legally privileged advice in the hearing bundle without obtaining appropriate advice or a tribunal direction.

Redaction is not a licence to hide relevant evidence. If a relevant document contains bank details, contact details, information about a child, medical information or another person's confidential material, consider whether a limited redaction is appropriate and whether you need a direction under rule 17 restricting disclosure or publication. Keep an unredacted original safe.

• No duplicate or superseded versions
• No private contact or banking data unless relevant
• No comments, highlights or tracked changes added to source documents
• No mediation, without-prejudice or privileged material included by mistake
• Every redaction recorded and defensible
• Unredacted originals preserved
• Any confidentiality application made before the deadline

Ask someone unfamiliar with the file to use the index to find three important documents. Then rehearse one issue from start to finish: issue-schedule row, witness statement paragraph, invoice or photograph, calculation and requested determination. If the route breaks, fix the index or cross-references before filing.

Prepare a short key-page list for your own hearing notes, but do not create a second unofficial pagination system. At the hearing, refer to the filed bundle page number so every participant is looking at the same page.

• Every direction complied with or covered by an application
• Every live issue linked to evidence
• Every witness exhibit present
• Every total traceable to source figures
• Three sample documents found from the index
• All cross-references checked after final pagination
• Costs documents included only where required
• One final version retained exactly as filed