How to Prepare an Evidence Bundle for Court
A practical guide to preparing a paginated, indexed bundle of documents for a County Court, Employment Tribunal, or other civil hearing.
Overview
An evidence bundle (or 'hearing bundle') is a single, organised collection of all the documents relevant to a court or tribunal hearing. Good bundle preparation is one of the most practical things you can do to help your case — judges and tribunals work from the bundle throughout the hearing and appreciate a clear, logical, well-indexed document. Poor bundles — with missing documents, illogical ordering, or illegible copies — create a bad impression and waste time in the hearing.
Step-by-Step Process
Identify All Relevant Documents
Gather every document that is relevant to the case — including documents that may help the other side's case. In civil litigation you have a duty of disclosure under CPR r.31. In employment tribunals, both parties must disclose all documents relevant to the issues in the case. Start with: pleadings (claim form, particulars, defence), key correspondence, contracts, policies, financial records, and any expert reports.
- Start with the documents you know you have, then consider what you might be missing
- Check whether you need to request any documents from the other side (via a disclosure request or order)
- In employment cases, the respondent usually prepares the bundle — check it carefully and request missing documents
- If a document is relevant but damaging to your case, you must still disclose it under your duty of disclosure
Agree the Bundle with the Other Side
Agree the bundle contents with the other party if possible — an 'agreed bundle' is more efficient. Send the other party a draft index and invite them to suggest additions or deletions. In the County Court and Employment Tribunal, practice directions require the parties to try to agree a single composite bundle. If agreement cannot be reached, prepare separate bundles for your documents and indicate the disputed documents.
- An agreed bundle avoids disputes at the hearing about whether specific documents are admissible
- In the Employment Tribunal, the respondent usually takes the lead on bundle preparation
- If the other side is unrepresented, offer to prepare the bundle yourself
Organise the Documents Logically
Arrange documents in the bundle in a logical order — usually chronological, but sometimes by subject matter (e.g. correspondence section, contracts section, financial records section). For chronological bundles, the earliest document appears first. For subject bundles, create separate tabs for each topic with a clear index. Ensure all documents are legible — copies of original documents must be clear.
- Chronological order is the default for most civil hearings — it helps the judge follow the sequence of events
- Separate large bundles into volumes (e.g. Volume 1: Pleadings; Volume 2: Correspondence; Volume 3: Financial records)
- Scan documents at a minimum of 300 dpi if preparing an electronic bundle
- Remove duplicates — multiple copies of the same email thread are a common problem
Paginate, Index, and Tab the Bundle
Number every page sequentially from page 1 through to the last page. Create a clear index listing: the bundle tab number (if used), the document description, and the page number. For paper bundles, use dividers or tabs at the beginning of each section. For electronic bundles (PDF), create bookmarks for each document. The pagination must be accurate — judges and advocates use page numbers to refer to specific documents during the hearing.
- Use a PDF editor (Adobe Acrobat, PDF24, or similar) to add page numbers and bookmarks to electronic bundles
- Court electronic bundles usually need to be searchable (OCR text — not scanned images)
- Print the index on the first page of the bundle — it is the road map
- Number pages at the bottom centre or bottom right — not obscuring any text
File and Serve the Bundle
File the required number of copies with the court or tribunal (usually 4 copies for Employment Tribunal: judge + 2 lay members + one for use) and serve a copy on the other party, by the deadline in the directions. Most courts now accept electronic bundles by email or via an upload portal. Keep a copy for yourself. After the hearing, if the court gave you back a bundle, check whether there are judge's annotations — these can be informative if you need to appeal.
- Always meet the deadline for filing the bundle — late bundles create a poor impression and may lead to adverse costs orders
- For the Employment Tribunal, the bundle should be filed at least 7 days before the hearing (or as directed)
- For the County Court, check the directions order — usually 14–21 days before the hearing
- Electronic bundles should not exceed the portal's file size limit — compress images if necessary
Costs
Important Warnings
Do not add documents to the bundle after it has been filed and served without the court's permission and notifying the other side — this can lead to adjournments and costs orders.
The bundle must include documents relevant to the other party's case as well as your own — selective disclosure is a breach of your duty and will be viewed very seriously.
Electronic bundles must be in a single searchable PDF for most courts — multiple separate files are not acceptable.