FHDRA Hearing: How to Prepare Your Bundle

Last updated: January 2026

This article provides general information only and does not constitute legal advice. Every case is unique — consider seeking professional legal advice for your specific circumstances. Court requirements may vary; always verify current Practice Directions with official sources.

Quick Answer

The First Hearing Dispute Resolution Appointment (FHDRA) is the first substantive court date in child arrangements proceedings. CAFCASS receives over 238 new private law cases per working day per GOV.UK Family Court Statistics. The FHDRA bundle should follow Practice Direction 27A Chapter 7 — Bates numbering (A1, A2, B1, B2 restarting per section), a detailed index, and PDF bookmarks. Most FHDRAs are listed for one hour and many cases settle at this stage.

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What Is an FHDRA?

Your first court date is approaching. The First Hearing Dispute Resolution Appointment – universally known as the FHDRA – is when you first appear before a judge in child arrangements proceedings. Whether you're represented by a solicitor or navigating this yourself, proper preparation can make all the difference.

The centrepiece of that preparation is your court bundle. Get it right, and you present yourself as organised and professional. Get it wrong, and you're scrambling for documents while a judge waits impatiently.

The FHDRA serves multiple purposes:

• Identifying the issues – What do the parties actually disagree about?
• Safeguarding checks – CAFCASS presents its initial findings
• Dispute resolution – Can an agreement be reached today?
• Case management – If not, what happens next?

"The first hearing is designed to help parents and carers resolve disputes about their children wherever possible. A CAFCASS Family Court Adviser will usually be present to help the court understand safeguarding issues and to assist with dispute resolution." — CAFCASS

Most FHDRAs are listed for one hour, sometimes less. That's not much time, which is why being prepared matters.

FHDRA Statistics and Context

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The FHDRA Bundle Requirements

Practice Direction 27A sets out what court bundles must contain and how they should be formatted. For an FHDRA, requirements are relatively straightforward:

Essential Documents

Your bundle should include:

Position Statement

This is crucial. A position statement is a short document (usually 2-3 pages) setting out:

Keep it focused. Judges don't want to read lengthy narratives. They want to understand the dispute quickly so they can help resolve it.

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Formatting Your Bundle

Practice Direction 27A specifies how bundles should be presented:

Pagination

For private law children proceedings, PD27A Ch 7.2 requires Bates numbering — each section has a letter and documents within the section are labelled from 1. A typical FHDRA bundle reads A1, A2, A3, B1, B2, C1, C2 …, with the numbers restarting at 1 in every new section. Labels should appear in the same position on each page — typically bottom centre or bottom right.

Index

Include a detailed index at the front listing:

• Document description
• Date of document
• Page numbers where it appears

This helps everyone find documents quickly during the hearing.

Document Order

Arrange documents in the section order set out in PD27A Ch 7.3. A typical FHDRA bundle uses only the sections that apply to your case:

• Section A — Preliminary and case management documents (index, case summary, position statements)
• Section B — Applications and orders (C100, C1A if filed, any previous orders)
• Section C — Statements and affidavits (dated, no exhibits)
• Section E — CAFCASS safeguarding letter or any Section 7 report
• Section I — Other relevant documents (arranged by appropriate divisions)

Within each section, documents run in chronological order.

Electronic Bundle Requirements

Most courts now require electronic bundles in PDF format. According to Practice Direction 27A:

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Creating Your Bundle: Step by Step

Step 1: Gather Your Documents

Collect everything that might need to go in the bundle. Better to have too much and edit down than to discover something's missing the night before.

Step 2: Sort and Select

Not every document belongs in an FHDRA bundle. Include only what's necessary to understand the current issues. Detailed evidence can wait for later hearings if needed.

Step 3: Write Your Position Statement

Do this early – it helps clarify your own thinking. Include:

Introduction (2-3 sentences) State who you are and what the case is about.

Background (half a page maximum) When did you meet? When were children born? When did you separate? Keep it factual and neutral.

Current arrangements (quarter page) Where do the children live? What contact happens? What's working and what isn't?

Your proposals (half page) Be specific about what you want. Not "I want more time with my children" but "I propose that the children spend every other weekend with me, Friday 4pm to Sunday 6pm, plus one midweek overnight on Wednesdays."

Issues requiring resolution (half page) What are the sticking points? Be honest about what you can't agree on.

Attitude to further steps (quarter page) Would you be willing to try mediation? Are there safeguarding concerns needing investigation? Do you think a Section 7 report is necessary?

Step 4: Paginate and Index

Once documents are in order, add page numbers and create your index.

Automatic Bundle Formatting: Creating a compliant FHDRA bundle manually is time-consuming. BundleCreator.co handles pagination, indexing, bookmarking, and PDF optimisation automatically—letting you focus on the substance of your case rather than formatting technicalities.

Step 5: Convert to PDF

Create a single PDF with all documents combined in order. Ensure text is searchable (most PDF software has an OCR function for scanned documents).

Step 6: Add Bookmarks

Create bookmarks for each main section, matching your index entries. This allows the judge to navigate easily during the hearing.

Step 7: Check File Size

Courts struggle with massive files. If your bundle exceeds 20MB, compress images or split into volumes.

Step 8: File and Serve

Submit to the court by the deadline (usually 2 clear working days before the hearing). Send a copy to the other party at the same time.

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Common FHDRA Bundle Mistakes

Mistake 1: Last-Minute Preparation

Starting the night before guarantees stress and errors. Begin at least a week ahead.

Mistake 2: Missing Documents

Realising in court that you don't have the CAFCASS letter is embarrassing and potentially costly. Check and double-check.

Mistake 3: Excessive Volume

A first hearing doesn't need 200 pages of WhatsApp messages. Keep it focused. There'll be time for detailed evidence if the case continues.

Mistake 4: Poor Quality Scans

Illegible documents frustrate everyone. Scan at reasonable resolution and check readability.

Mistake 5: No Pagination

Nothing says "unprepared" like a bundle without labels. The judge will literally not be able to direct everyone to the same page. Use the Bates scheme required by PD27A Ch 7.2 (A1, A2, B1, B2 …) and make sure the PDF page labels match the index exactly.

Mistake 6: Emotional Position Statements

Your position statement should inform, not persuade through emotion. Accusations like "my ex is a narcissist" or lengthy complaints about perceived wrongs won't help. Focus on the children.

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What Happens at the FHDRA

Understanding the hearing helps you prepare appropriately.

Before You Go In

Arrive early. Find the right courtroom. If you have a solicitor, meet them beforehand to discuss approach.

The CAFCASS officer may want to speak to each parent briefly before the hearing. Cooperate with this – they're trying to identify scope for agreement.

In the Courtroom

The judge will usually:

1. Check everyone's present and introduce themselves
2. Confirm they've read the papers
3. Ask CAFCASS to summarise their safeguarding checks
4. Ask each party what they want
5. Explore whether agreement is possible
6. Make orders (either by consent or about next steps)

Be respectful, stand when speaking (unless told otherwise), and address the judge as "Sir" or "Madam" (or "Your Honour" in higher courts).

If You Reach Agreement

The judge will draw up an order reflecting what you've agreed. Read it carefully before it's finalised. Once sealed, that order is binding.

If You Don't

The judge gives directions about what happens next. This might include:

Make sure you understand each direction. Ask if anything's unclear.

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After the FHDRA

If your case didn't settle, you'll need to prepare a more comprehensive bundle for future hearings. The FHDRA bundle forms the foundation, but you'll add:

• Witness statements
• Detailed evidence
• Expert reports
• The Section 7 report (when completed)

Start organising early. The bundles get more complex as proceedings progress.

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How BundleCreator Helps

Preparing court bundles is time-consuming and easy to get wrong. BundleCreator.co automates the difficult parts:

Rather than spending hours on formatting, you can focus on what matters: preparing your case and your position statement.

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Frequently Asked Questions

What is an FHDRA hearing?

The First Hearing Dispute Resolution Appointment is your first substantive court date in child arrangements proceedings. The judge, often with a CAFCASS officer present, will try to help you reach agreement. If that's not possible, they'll give directions for next steps.

How long is an FHDRA hearing?

Most FHDRAs are listed for one hour, though complex cases may take longer. Courts are very busy, so efficient use of time is expected.

What should be in my FHDRA bundle?

At minimum: C100 application and response, C1A (if applicable), CAFCASS safeguarding letter, any existing court orders, and your position statement. The bundle must comply with Practice Direction 27A formatting requirements.

How do I format my court bundle?

For private law children proceedings, PD27A Ch 7.2 requires Bates numbering (A1, A2, B1, B2 …, with numbers restarting in each section), a detailed index at the front, and a PDF format with bookmarked sections. File size should be under 20MB. BundleCreator.co handles this automatically.

When do I need to file my FHDRA bundle?

Typically 2 clear working days before the hearing, though check your court's specific requirements. You must also serve a copy on the other party at the same time.

What is a position statement?

A 2-3 page document summarising your case, your proposals, and the issues in dispute. It helps the judge understand the case quickly so they can assist with resolution.

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Your FHDRA Bundle Checklist

• C100 application – your original application
• Response – the other party's response (if received)
• C1A form – if allegations of harm were made
• CAFCASS safeguarding letter – obtained from court file
• Existing orders – any current orders about the children
• Position statement – 2-3 pages, focused on proposals
• Index – with Bates labels for each document
• Pagination – Bates labels A1, A2, B1, B2 … with numbers restarting in each section
• Bookmarks – matching index entries
• File size – under 20MB
• Filing – submitted 2+ days before hearing

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This guide provides general information about FHDRA bundles in England and Wales. It is not legal advice. For advice specific to your situation, consult a qualified family solicitor.

Sources:

• GOV.UK Family Court Statistics Q3 2025
• Practice Direction 27A
• CAFCASS Court Process Information
• CAFCASS Data
• Family Procedure Rules