Multi-Track Personal Injury Trial Bundle: From Pleadings to Authorities

Last updated: 7 May 2026

Quick answer

A multi-track personal injury trial bundle (CPR Part 29, claims over £25,000 or complex liability) is conventionally structured in nine sections (this is a working model, not a rule-mandated structure — the only mandated content is set by PD 39A para 3.2): pleadings and case management; witness statements; medical records; medical experts (breach, causation, condition and prognosis); non-medical experts (engineering, care, accommodation, deputyship); joint statements; quantum schedules; inter-party correspondence; authorities. Continuous pagination throughout; A4 portrait; OCR'd; hyperlinked index; PDF bookmarks at section and document level. Filed not less than 3 and not more than 7 days before trial under CPR rule 39.5 and PD 39A para 3.10. The bundle commonly runs 1,500-3,500 pages for catastrophic-injury claims; less complex cases 500-1,500 pages.

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When the multi-track applies

CPR Part 26 governs track allocation. The multi-track is the default for:

• Claims over £25,000 (the upper limit of fast-track jurisdiction)
• Claims of any value where the trial is likely to last more than one day
• Claims involving complex liability (reconstruction evidence, multiple defendants, novel duty-of-care points)
• Catastrophic-injury claims (severe brain injury, tetraplegia, complex obstetric injury)
• Clinical negligence multi-track (most clinical negligence ends here)

Track allocation is decided at the case management conference (CMC) after pleadings have closed. The CMC also produces the directions order setting out trial preparation timelines, expert evidence permissions, and disclosure requirements.

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The nine-section structure

A standard multi-track PI trial bundle:

Section A — Pleadings and case management

• A1: Claim Form (N1)
• A2: Particulars of Claim
• A3: Defence (and any Counterclaim)
• A4: Reply (where served)
• A5: Case Management Order(s)
• A6: Pre-Trial Review order (where one was held)
• A7: List of Issues for trial (agreed where possible)

Section B — Witness statements

Each witness gets a sub-section. Order is typically: claimant first, then claimant's lay witnesses, then defendant's lay witnesses. Each statement is followed by the witness's exhibits, paginated continuously.

• B1: Claimant's witness statement(s)
• B2: Claimant's family/lay witness statements
• B3: Defendant's witness statement(s)
• B4: Defendant's lay witness statements
• B5: Hearsay notice and any responses (CPR Part 33)

Section C — Medical records

The records are arranged chronologically across all sources, OCR'd throughout. Bookmarks for each treating clinician/institution.

• C1: GP records (full set, chronological)
• C2: A&E records
• C3: Hospital admissions and discharge summaries
• C4: Consultant outpatient letters
• C5: Imaging and radiology reports
• C6: Theatre notes (where relevant)
• C7: Anaesthetic records (where relevant)
• C8: Drug charts and medication records
• C9: Therapy notes (physiotherapy, OT, SALT, psychological therapy)
• C10: Other treating-provider records (ambulance reports, occupational health, dental)

Section D — Medical experts: breach and causation

• D1: Claimant's breach-of-duty expert(s)
• D2: Defendant's breach-of-duty expert(s)
• D3: Joint statement on breach
• D4: Claimant's causation expert(s)
• D5: Defendant's causation expert(s)
• D6: Joint statement on causation
• D7: Inter-expert correspondence and answers to CPR Part 35 questions

Section E — Medical experts: condition and prognosis

• E1: Claimant's condition and prognosis expert(s)
• E2: Defendant's condition and prognosis expert(s)
• E3: Joint statement
• E4: Life expectancy expert (catastrophic injury cases)

Section F — Non-medical experts

For RTA cases this is typically engineering and reconstruction. For catastrophic injury this is care, accommodation, deputyship, vocational rehabilitation, and educational expert evidence.

• F1: Engineering / accident reconstruction expert
• F2: Care expert (claimant and defendant)
• F3: Accommodation expert (post-Swift v Carpenter methodology)
• F4: Deputyship cost expert (Court of Protection deputy)
• F5: Vocational rehabilitation expert
• F6: Educational psychologist (brain-injured children)

Section G — Joint statements (consolidated)

Where a separate consolidated joint-statements section is required by the trial directions, place all joint statements together for ease of reference. Otherwise joint statements sit with the relevant expert section above.

Section H — Quantum schedules

• H1: Claimant's Schedule of Loss
• H2: Defendant's Counter-Schedule
• H3: CRU certificate (most recent within 28 days of trial — see CRU Certificates and Schedule of Loss)
• H4: Joint statement on quantum (where prepared)
• H5: Updating Schedule of Loss (where the case has run on)

Section I — Inter-party correspondence and authorities

• I1: Without-prejudice correspondence (excluded from the trial bundle except where r.36.16(3)/(4) exception applies — see Part 36 treatment below)
• I2: Open correspondence on the live issues (where relied on)
• I3: Authorities (claimant)
• I4: Authorities (defendant)

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Filing deadlines

CPR rule 39.5 with Practice Direction 39A para 3.10:

• Not less than 3 days before trial: bundle to be filed
• Not more than 7 days before trial: bundle to be filed
• Identical copy to be served on each party

For trials in the King's Bench Division, the e-bundle is uploaded to the relevant electronic filing system (CE-File for the Rolls Building, MyHMCTS for some County Court hearing centres). Paper bundles are increasingly rare for civil PI trials.

The bundle's contents must be agreed where possible. Where the parties cannot agree, the disagreement is recorded at the front of the bundle in a covering note, and each party's contested documents are clearly flagged.

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Common multi-track bundle problems

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Part 36 offers in the bundle

Part 36 offers (CPR Part 36) are NOT in the trial bundle until liability and quantum have been determined — under r.36.16(2) the fact and terms of an offer must not be communicated to the trial judge until the case has been decided.

Limited exceptions under r.36.16(3) and (4) — for example, where the offer is relevant to an issue actually before the court (a costs interim, a strikeout, a preliminary issue). In a standard liability+quantum trial, Part 36 offers stay out of the trial bundle entirely and surface for the costs assessment afterwards.

BundleCreator's Personal Injury template separates the trial bundle from the costs bundle so the Part 36 traffic is only ever included where the rules permit.

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How BundleCreator helps

BundleCreator's Personal Injury template structures the trial bundle in the nine-section order above, with continuous pagination, OCR'd medical records, hyperlinked index, and section bookmarks. Each expert's report is bookmarked individually; the hyperlinked index lets trial counsel jump between (for example) the claimant's breach expert and the defendant's response on the same issue.

For catastrophic-injury cases the bundle commonly splits across multiple volumes paginated continuously — Volume 1 (Sections A-C), Volume 2 (Sections D-F), Volume 3 (Sections G-I). The output is sub-bundle PDFs ready for upload to CE-File or MyHMCTS, plus a master index covering all volumes.

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Frequently asked questions

How big does a multi-track PI bundle normally run?

For a standard multi-track RTA or EL/PL case: 500-1,500 pages. For a clinical negligence multi-track: 1,500-3,500 pages. For catastrophic-injury cases (severe brain injury, complex obstetric, full-life-care claims): 3,000-5,000 pages, usually split across multiple sub-bundles. BundleCreator handles individual bundles up to 1,000 pages each — split across volumes for larger cases.

Do the parties have to agree the bundle contents?

Yes, where possible. CPR PD 39A para 3.2 requires the parties to consult about the contents of the trial bundle and the order of documents. Disagreement on inclusion is recorded; the trial judge resolves it at the start of the trial.

What if a key document is missing?

Apply to the court for a direction, or include with a clear note explaining the difficulty. The court takes a pragmatic view — but if the missing document goes to a live issue, the trial may be adjourned.

Can witness statements be in narrative form or do they need to follow a strict structure?

CPR PD 32 governs the form of witness statements generally. They must be in the witness's own words, in the first person, with paragraphs numbered, in chronological order where possible, and signed with a statement of truth (PD 22). PD 57AC imposes additional strict requirements on trial witness statements in the Business and Property Courts (Commercial Court, Chancery, TCC, IPEC, Companies Court) — including a confirmation by the witness and a certificate of compliance from the legal representative. PD 57AC does NOT apply to PI trials in the King's Bench Division or County Court, where PD 32 alone governs.

How do CPR Part 35 expert questions appear in the bundle?

CPR Part 35 questions are written questions to an expert post-report. The questions and the expert's answers are appended to the expert's report in the bundle — usually as an annex to the relevant report in Section D, E, or F.

Where do schedules of loss go if the case has been settled in part?

A partly-settled case (e.g. liability admitted; quantum tried) typically has a settlement order in Section A and an updating Schedule of Loss in Section H reflecting the agreed liability position. The Counter-Schedule responds on the live quantum issues only.

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Further reading

• CPR Part 29 — Multi-track
• CPR Part 32 and PD 32 — Evidence and witness statements
• CPR Part 35 and PD 35 — Experts and assessors
• CPR Part 39 and PD 39A — Trial preparation
• CRU Certificates and Schedule of Loss in Personal Injury Trial Bundles
• Engineering Expert Evidence in RTA Trials: When and How to Bundle