Common Court Bundle Mistakes That Can Derail Your Family Court Case

Last updated: March 2026

Quick Answer

Family court bundles are rejected or criticised more often than most people realise. The mistakes are usually avoidable: missing documents, wrong pagination, irrelevant material, and late filing. Each one risks adjournments, costs orders, and damage to your credibility with the judge. Here are the ten most common errors and how to avoid them.

---

Why Bundle Mistakes Matter So Much in Family Court

Family judges typically read bundles the evening before a hearing. They may have six or seven bundles to review in a single night. If yours is disorganised, they will spend less time on it. If key documents are missing, they will form an incomplete picture of your case. If the pagination is wrong, they cannot follow references made during the hearing.

The consequences are not abstract. Courts have repeatedly observed that poor bundle preparation contributes to delays that are directly contrary to the child's welfare. The President of the Family Division has emphasised in guidance on e-bundles that compliant bundles are essential to the efficient administration of justice. Family cases involve real people waiting for real decisions about their children and their finances. Every avoidable delay matters.

---

Mistake 1: Missing Documents the Court Has Directed

This is the most common and most damaging error. The directions order will specify exactly what must be in the bundle. If it says the bundle must contain the C100 application, the Cafcass safeguarding letter, and all previous court orders, those documents must be there.

Documents people consistently forget:

• The original application form (C100, FL401, or Form A)
• The other party's response (C7 acknowledgement form)
• Previous court orders, especially older ones from earlier hearings
• The Cafcass safeguarding letter or section 7 report
• The MIAM certificate or exemption evidence
• Case management orders that set out the timetable

The consequence: The judge may not be able to proceed. If a critical document like a section 7 report is missing from the bundle, the hearing may be adjourned so the bundle can be corrected. That adjournment could delay your case by two to three months.

How to avoid it: Go through your directions order line by line with a highlighter. Tick off each document as you add it to the bundle. If you cannot find a document, contact the court office to request a copy before the filing deadline.

---

Mistake 2: Wrong Pagination

Pagination errors come in several forms:

• Starting from the wrong page. The index is page 1. Everything else follows sequentially. Some people start numbering from the first substantive document, leaving the index unnumbered.
• Gaps in numbering. Pages jump from 34 to 37. This usually happens when a document is removed but the remaining pages are not renumbered.
• Using the wrong pagination system for the proceedings type. PD27A splits the rule by proceedings type: non-financial-remedy Family proceedings (children, FLA, adoption — Ch 7.2) require Bates numbering with per-section restart (A1, A2, A3, B1, B2, B3 — Section B opens at B1, not at the next number after Section A); financial remedy proceedings (Ch 6.2) require Arabic numerals consecutive through the whole bundle with PDF page labels matched. Getting the wrong one exposes you to the Ch 3 non-compliance consequences.
• PDF page numbers not matching printed numbers. For e-bundles, the page number displayed by the PDF reader must match the number printed on the page and the number in the index. If your PDF reader shows page 50 but the printed number says page 48, the judge will be confused every time someone says "turn to page 50."

The consequence: When a barrister says "the court will see at page 127 that..." and page 127 contains the wrong document, the hearing grinds to a halt. Everyone flips through the bundle trying to find the right page. Multiply this by every document reference throughout a full-day hearing and you have wasted potentially an hour of court time.

How to avoid it: After assembling the bundle, go through every single page and verify the numbering. For e-bundles, open the final PDF and check that clicking page 1 in the index takes you to the actual first page of that document.

---

Mistake 3: No Index, or a Useless One

Some bundles arrive at court with no index at all. Others have an index that lists "documents" with no page numbers, dates, or descriptions. Both are essentially useless.

A proper index must include:

• The section reference (A1, A2, B1, etc.)
• The full name of the document
• The date of the document
• The page number where it starts in the bundle

A bad index looks like this:

1. Application
2. Order
3. Statement
4. Report
5. Emails

A good index looks like this:

The consequence: Without a functioning index, the judge has to leaf through the entire bundle to find each document. This wastes time and irritates the court. In multi-day hearings, advocates will be referring to documents by page number constantly. Without accurate page references, the hearing becomes chaotic.

---

Mistake 4: Including Irrelevant Material

This is where emotions override judgment. Litigants in person, understandably upset about their situation, often want to include every piece of evidence they have. Text messages going back years. Screenshots of social media posts. Emails copied to friends and family members. Photographs of trivial disagreements.

PD27A imposes a 350-page limit for a reason. The judge does not need to see 47 pages of WhatsApp messages to understand that communication has broken down. A representative selection of four or five messages that illustrate the key points is far more effective.

Material that should almost never be in a bundle:

• Screenshots of social media posts (unless they contain specific threats or admissions)
• Text messages that simply show an argument without any relevance to the legal issues
• Character references from friends and family (the court gives these very little weight)
• Letters or emails to third parties that do not involve the other party
• Duplicate copies of the same document
• Correspondence between you and your former solicitor

The consequence: Including irrelevant material has two effects. First, it pushes your bundle over the 350-page limit, which means you either need court permission or you need to cut something that actually matters. Second, it buries your important evidence. A judge who has to wade through 30 pages of text messages to find the one relevant exchange is less likely to spot it than if you had included only that exchange.

---

Mistake 5: Exceeding the 350-Page Limit Without Permission

Practice Direction 27A states that bundles for hearings lasting one day or less should not exceed 350 pages. For longer hearings, the limit may be higher, but only with the court's agreement.

Many litigants simply ignore this limit and file bundles of 500, 600, or even 800 pages. This does not impress the judge. It tells them you have not thought carefully about what matters.

How to stay within the limit:

• Include only documents the court has directed
• Remove duplicate copies
• Summarise lengthy correspondence rather than including every email
• Use a schedule or chronology to present facts rather than including the underlying documents
• Ask yourself, for each document: "Does the judge need to read this to decide the issues at this hearing?"

The consequence: The court may refuse to accept an oversized bundle and direct you to reduce it. This costs you time and may result in a last-minute scramble to remove documents. In some cases, the judge will simply stop reading after 350 pages and ignore everything beyond that point.

If you genuinely need more than 350 pages, apply to the court in advance. Explain which documents require inclusion and why. The court will usually grant permission if the request is reasonable, particularly in complex financial remedy cases or cases involving allegations of serious harm.

---

Mistake 6: Late Filing

The standard deadline for filing bundles in family proceedings is 7 working days before the hearing, though your specific directions order may set a different date. "Working days" means Monday to Friday, excluding bank holidays.

If your hearing is on a Wednesday, 7 working days before is the Wednesday of the previous week. Not the Tuesday. Not the Thursday. The Wednesday.

The consequence: Filing late deprives the judge of preparation time. If your bundle arrives the day before a hearing, the judge may not have read it. They will then either proceed without having read your evidence (bad for you) or adjourn the hearing (bad for everyone).

Under rule 4.6 of the Family Procedure Rules 2010, the court can impose sanctions for non-compliance with directions, including costs orders. The Court of Appeal has repeatedly emphasised that compliance with court directions, including bundle deadlines, is not optional — and that practitioners and litigants who ignore deadlines risk costs orders under FPR rule 28.1.

How to avoid it: Put the filing deadline in your calendar with a reminder three days before. Start preparing the bundle at least two weeks before the deadline. If you realise you cannot meet the deadline, apply for an extension immediately rather than simply filing late.

---

Mistake 7: Poor Document Quality

Judges read bundles on screens and sometimes print them. Documents that are blurry, sideways, upside down, or have text cut off at the margins are difficult or impossible to read.

Common quality problems:

• Photographs of documents taken with a phone camera at an angle
• Scans with a dark background that makes text hard to read
• Pages that are sideways (landscape) when they should be portrait
• Text that runs off the edge of the page because the original was not aligned properly on the scanner
• Low-resolution images where handwriting is illegible

The consequence: If the judge cannot read a document, it might as well not be in the bundle. You cannot rely on evidence the court cannot see. In extreme cases, the judge may draw an adverse inference from your inability to produce a legible copy of a document you say is important.

How to avoid it: Use a proper scanner or a scanning app that corrects for alignment and lighting. Check every page of the final bundle for legibility. If a document is genuinely illegible (an old handwritten letter, for example), consider providing a typed transcript alongside it.

---

Mistake 8: Not Complying with the Judge's Specific Directions

Generic PD27A alignment is not enough. Your specific directions order may contain requirements that go beyond the standard rules.

For example, a judge may direct:

• "The bundle shall include a chronology agreed between the parties"
• "Position statements shall be filed separately, not in the bundle"
• "The applicant shall prepare a schedule of allegations in Scott Schedule format"
• "The bundle shall contain only documents relating to the welfare issues"

If the order says "agreed chronology" and you file a chronology the other party has not seen, you have not complied. If the order says position statements go separately and you put yours in the bundle, you have not complied.

The consequence: Non-compliance with specific directions is taken more seriously than non-compliance with general practice directions. The judge made a specific order for a reason. Ignoring it suggests you either did not read the order or chose not to follow it. Neither reflects well on you.

---

Mistake 9: Failing to Agree the Bundle with the Other Party

Practice Direction 27A requires that the bundle be agreed between the parties. This means both sides should agree on which documents are included. It does not mean both sides must agree on the content or truth of those documents.

In practice, the person preparing the bundle sends a draft index to the other party and asks whether they want any additional documents included or any documents removed. If agreement cannot be reached, the bundle preparer should include the disputed documents but note on the index that they are "included at the request of [party name]" or "inclusion disputed by [party name]."

The consequence: If you file a bundle without consulting the other party, you may face criticism from the judge. The other party may turn up at the hearing with documents they say should have been included. The judge may then direct a revised bundle, potentially causing an adjournment.

Worse, if you deliberately exclude documents that the other party asked to include, the court may view this as an attempt to suppress evidence. This can seriously damage your credibility.

---

Mistake 10: Filing Multiple PDF Files Instead of One

This applies to e-bundles. The court expects a single PDF file containing all documents, paginated continuously with a clickable index. What courts frequently receive instead is an email with 15 separate PDF attachments.

The reason this matters: a judge cannot navigate between documents efficiently when they are in separate files. There is no continuous pagination. There is no index linking to page numbers. Each time the judge wants to cross-reference two documents, they have to open and close different files.

The consequence: Some courts will reject multiple-file submissions and require resubmission as a single PDF. Others will accept them but the judge will struggle during the hearing. Either way, it reflects poorly on your preparation.

How to avoid it: Combine all documents into a single PDF before filing. If you are not sure how to do this, most PDF readers (including the free ones) have a "combine" or "merge" function.

---

The Real Cost of Bundle Mistakes

The tangible consequences of bundle errors include:

• Adjournments: The hearing is postponed, typically by 2 to 4 months. Your case is delayed. The uncertainty continues.
• Costs orders: Under FPR rule 28.1, the court can order a party to pay the other side's costs if their conduct has been unreasonable. Filing a non-compliant bundle can be unreasonable conduct.
• Adverse inferences: If important documents are missing or illegible, the judge may infer that the missing evidence would not have supported your case.
• Wasted preparation: If you prepared a position statement referencing specific page numbers and those numbers are wrong, your oral submissions become confusing.
• Judicial frustration: Judges are human. A well-prepared bundle makes a good first impression. A chaotic one does the opposite. This will not determine the outcome of your case, but it does affect how the judge perceives your attention to detail and credibility.

---

How BundleCreator Can Help

Most of these mistakes come down to the mechanical work of bundle preparation: pagination, indexing, combining PDFs, and formatting. BundleCreator handles these tasks automatically, letting you concentrate on selecting the right documents and presenting your case. It is built around PD27A requirements, so the technical compliance is taken care of. You can start a 14-day trial to see whether it works for your case.