How to Write a Witness Statement for Family Court Proceedings

Last updated: March 2026

Quick Answer

A witness statement is your written evidence to the court. It sets out, in your own words, the facts you want the judge to know. In family proceedings, witness statements must comply with Practice Direction 27A and Part 22 of the Family Procedure Rules 2010. They must be written in the first person, divided into numbered paragraphs, contain a statement of truth, and be signed and dated. A good witness statement is clear, chronological, focused on relevant facts, and avoids emotional language or irrelevant detail. Getting it right can make the difference between the judge understanding your case and the judge being confused by it.

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Why Your Witness Statement Matters

In family court, the judge reads your witness statement before the hearing. By the time you walk into the courtroom, the judge has already formed an initial impression of your case based on what you have written.

Your witness statement is your chance to tell your story in a structured, coherent way. During the hearing, you will be asked to confirm it is true, and then the other party (or their solicitor) will cross-examine you on it. You will not usually be given the opportunity to make a speech or tell the judge everything from scratch — your statement does that job.

This is why it matters so much. A poorly written statement — one that is rambling, disorganised, or full of opinions instead of facts — makes the judge's job harder and weakens your case. A clear, well-structured statement makes your evidence accessible and persuasive.

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Format Requirements

Practice Direction 27A and FPR Part 22

Family court witness statements must comply with specific formatting requirements:

The Heading

Your witness statement should begin with a heading that identifies:

IN THE FAMILY COURT AT [LOCATION]

Case Number: [XX12345]

BETWEEN:

[APPLICANT NAME]                          Applicant

-and-

[RESPONDENT NAME]                         Respondent

WITNESS STATEMENT OF [YOUR NAME]

I, [FULL NAME], of [ADDRESS], state as follows:

If you are a litigant in person, you may not know all these details. At minimum, include the case number and the names of the parties.

The Statement of Truth

Every witness statement must end with the statement of truth:

"I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against any person who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth."

This is not optional. A witness statement without a statement of truth cannot be relied upon as evidence. Sign and date it below the statement of truth.

Get the format right automatically. BundleCreator.co includes witness statement templates pre-formatted with the correct heading, numbered paragraphs, and statement of truth. You write your evidence; the template ensures it meets the court's requirements.

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What to Include

Start with Your Background

The first few paragraphs should introduce you:

• Your full name, age, and occupation
• Your relationship to the other party and any children
• How long you have been involved in the proceedings
• Whether this is your first statement or a supplementary one

Set Out the Facts Chronologically

The body of your statement should present the facts in the order they happened. Chronological structure is the clearest and most persuasive approach.

For each significant event, include:

• When it happened (date and approximate time)
• Where it happened (specific location)
• What happened (exactly what was said and done)
• Who was present
• What you did in response
• Any evidence that corroborates your account (and where it can be found in the bundle)

Focus on Relevant Facts

Not everything that has happened in your relationship is relevant to the court's decision. Focus on the facts that relate to the issues the court will decide:

In child arrangements cases, focus on:

• The children's current arrangements and how they are working
• Your involvement in the children's lives (school, activities, healthcare)
• Any welfare concerns and the evidence supporting them
• What arrangements you are proposing and why they serve the children's interests
• The children's wishes and feelings (if age-appropriate)

In financial remedy cases, focus on:

• Your financial position (income, assets, debts, needs)
• The other party's financial position (as far as you know it)
• Contributions to the marriage (financial and non-financial)
• Your needs and the needs of any children

In fact-finding hearings, focus on:

• The specific allegations in the Scott Schedule
• Detailed accounts of each alleged incident
• Any corroborating evidence
• The impact of the alleged behaviour

Reference Your Exhibits

Whenever you mention a document that supports your evidence, reference the exhibit:

"On 15 March 2024, the respondent sent me a series of threatening text messages. I refer to the transcript of these messages at Exhibit AB/3 (pages 94–97 of the bundle)."

This allows the judge to check the supporting evidence immediately, rather than searching through the bundle.

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What Judges Want to See

Family judges read hundreds of witness statements. Here is what they consistently say makes a good one:

Clarity

Write in plain English. Avoid legal jargon unless you are certain of its meaning. Short sentences are better than long, complex ones. If a point can be made in one sentence, do not use three.

Specificity

"The respondent was aggressive" tells the judge very little. "On 22 June 2024 at approximately 9pm, the respondent shouted at me in the kitchen, called me [specific words], and threw a plate against the wall" tells the judge a great deal.

Honesty

Include facts that do not help your case as well as those that do. If you made mistakes, acknowledge them. Judges are experienced at detecting statements that only present one side of the story, and selective honesty undermines your credibility more than honest admissions ever could.

Brevity

A witness statement for a one-day hearing should rarely exceed 15 to 20 pages. For a half-day hearing, 8 to 12 pages is usually sufficient. Judges have repeatedly criticised excessively long witness statements. The revised PD27A reinforces the expectation that statements should be proportionate to the issues.

Focus on the Children

In children proceedings, the court's paramount consideration is the welfare of the child. Your statement should demonstrate that you understand this. Statements that focus primarily on attacking the other parent, rather than on the children's needs, do not serve your case well.

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Common Mistakes to Avoid

1. Writing in the Third Person

Witness statements must be in the first person. Write "I saw..." not "The applicant saw..." This seems obvious, but it is a surprisingly common error.

2. Including Opinions Instead of Facts

"The respondent is a terrible parent" is an opinion. "On three occasions in January 2024, the respondent failed to collect the children from school, as recorded in the school's attendance log at Exhibit AB/5" is a fact. Opinions belong in submissions, not witness statements.

3. Excessive Emotional Language

It is natural to feel angry, hurt, or frightened. But witness statements should be factual, not emotional. "The respondent screamed abuse at me for twenty minutes while I was holding the baby" is powerful because it is factual. "The respondent was a monster who terrorised me relentlessly" is emotional and less persuasive.

4. Including Irrelevant Material

Everything in your statement should be relevant to the issues the court will decide. Your ex-partner's failure to wash up in 2018 is not relevant to a child arrangements dispute in 2026, unless it forms part of a relevant pattern of behaviour.

5. Not Numbering Paragraphs

This makes it impossible for the judge, the other party, and their solicitor to refer to specific parts of your evidence. "Paragraph 47 of the applicant's statement" is precise; "somewhere on page 8" is not.

6. Forgetting the Statement of Truth

Without the statement of truth, your witness statement is not valid evidence. Double-check before you file it.

7. Exceeding the Court's Page Limit

If the court has imposed a page limit on witness statements (increasingly common), you must comply. A statement that exceeds the limit without permission may be rejected or the excess disregarded.

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Supplementary Witness Statements

If events occur after you file your main witness statement, or if you need to respond to the other party's evidence, you may need to file a supplementary statement.

A supplementary statement should:

• Be clearly labelled (e.g., "Second Witness Statement of [Name]")
• Explain why the supplementary statement is necessary
• Address only new matters or matters arising from the other party's evidence
• Not repeat what is already in your first statement
• Have its own statement of truth

Check whether the court's directions allow supplementary statements. If they do not, you may need to apply for permission before filing one.

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Witness Statements from Other People

You may want to include witness statements from people who can corroborate your evidence — family members, friends, neighbours, professionals.

What Third-Party Statements Should Include

• The witness's full name, address, and relationship to the parties
• What they directly witnessed (not what you told them happened)
• Specific dates, times, and locations
• A statement of truth, signed and dated

Practical Considerations

• Ask early. Witnesses often need time to write their statements.
• Do not draft it for them. The statement must be in the witness's own words. You can explain the format requirements, but do not tell them what to say.
• Check whether they can attend court. If the other party disputes their evidence, they may need to attend for cross-examination. A statement from a witness who cannot be cross-examined carries less weight.

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How Your Statement Fits in the Bundle

Your witness statement goes in Section C of the PD27A bundle, along with all other witness statements and any Cafcass reports.

The bundle should contain:

• The applicant's statement(s) first
• The respondent's statement(s) second
• Statements from other witnesses
• Professional reports (Cafcass, social services)

Exhibits referenced in your statement go in Section E, cross-referenced by exhibit number.

Organise everything in one place. BundleCreator.co lets you upload your witness statement and exhibits, place them in the correct PD27A sections, and automatically generates page numbers that match the hyperlinked index. When you reference "Exhibit AB/3 at page 94," you can be confident the page number is accurate.

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Writing Tips for Non-Lawyers

If you have never written a legal document before, these practical tips will help:

Use a Logical Structure

1. Introduction (who you are)
2. Background (brief history of the relationship and children)
3. Chronological account of relevant events
4. Current position (where things stand now)
5. What you are asking the court to do (and why)

Write as You Would Speak (But More Carefully)

Your statement should sound like you — not like a lawyer. Use your natural vocabulary, but take more care with precision than you would in conversation.

Read It Aloud

Before filing, read your statement aloud. If a sentence is hard to say, it is probably hard to read. Simplify it.

Get Someone to Proofread

Ask a trusted friend or family member to read your statement. Not for legal advice, but for clarity: does it make sense? Is anything confusing? Have you left out anything important?

Print and Review

Reviewing a printed copy often catches errors that you miss on screen. Check paragraph numbers, exhibit references, page numbers, and dates.

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Using BundleCreator.co for Witness Statements

BundleCreator.co supports the entire witness statement process:

• Pre-formatted templates with the correct heading, numbered paragraphs, and statement of truth
• Exhibit management — upload supporting documents and link them to your statement
• Automatic pagination — page numbers update automatically as you add or remove documents
• PD27A-aligned bundle export — your statement is placed in the correct section with a hyperlinked index
• Built-in guidance — templates include prompts for what information to include in each section

Whether you are writing your first witness statement or your fifth, the software ensures the formatting is correct so you can concentrate on the substance of your evidence.

Start building your bundle with BundleCreator.co

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Frequently Asked Questions

How long should my witness statement be?

There is no fixed rule, but proportionality matters. For a one-day hearing, aim for 15 to 20 pages. For a half-day hearing, 8 to 12 pages. The revised PD27A emphasises that statements should be no longer than necessary. If the court has imposed a page limit, you must comply.

Can I attach text messages as exhibits?

Yes. Transcribe them into a typed document (with date, time, sender, and message content) and include the original screenshots as a separate exhibit. The transcription makes them readable; the screenshots prove authenticity.

What if I cannot remember exact dates?

Use your best recollection and be honest about the approximation. "In or around March 2024" is acceptable. "Sometime that year" is too vague. Check your phone, email, bank statements, or social media for dates you cannot recall from memory.

Can I change my witness statement after filing it?

You cannot amend a filed statement. If you need to correct an error or add new information, file a supplementary statement (with the court's permission if required). In the supplementary statement, explain the correction or addition.

Do I need to attend court if I have filed a witness statement?

In most cases, yes. If the other party disputes your evidence, the court will expect you to attend for cross-examination. A witness statement from someone who does not attend carries less weight — the judge cannot assess their demeanour or test their evidence.

What is the difference between a witness statement and a position statement?

A witness statement is your evidence — the facts you are presenting to the court. A position statement is a summary of your case for a specific hearing — what you are asking for and why. Both may be needed for the same hearing, but they serve different purposes.

Can I include evidence about the other party's behaviour towards other people?

Generally, the court is interested in behaviour relevant to the children's welfare or the issues in dispute. Evidence about how the other party treats their colleagues at work is unlikely to be relevant. Evidence about how they treat the children's step-siblings might be.

What happens if I lie in my witness statement?

Making a false statement verified by a statement of truth is a contempt of court, punishable by a fine or imprisonment. Beyond the legal consequences, being caught in a lie destroys your credibility. Judges may disbelieve everything else you have said if they conclude you have been dishonest about one matter.

Should I include social media evidence?

If it is relevant, yes. Print or screenshot the relevant posts, messages, or profiles with dates visible. Include them as exhibits. Be aware that the other party may also present your social media activity — so check your own posts before the hearing.

Can a McKenzie Friend help me write my witness statement?

A McKenzie Friend can assist you with organising your thoughts and formatting the document, but the statement must be in your own words and reflect your own evidence. The McKenzie Friend should not draft the statement for you or tell you what to say.

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This article provides general information about writing witness statements for family court proceedings in England and Wales. It is not legal advice. For guidance specific to your case, consult a qualified family law solicitor.