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Preparing for Court

How to Write a Witness Statement for Family Court

Step-by-step guide to writing a family court witness statement in England and Wales: format, exhibits, and the exact statement of truth.

Best for the Children Editorial·11 min read·June 3, 2025·Updated October 14, 2026

You open the court order and one line stops you: file and serve a witness statement by a set date. You have plenty to say, but you have never written anything for a judge. A good family court witness statement is your own account, in the first person, set out in numbered paragraphs. It separates what you saw from what you were told, points to supporting documents (called exhibits), and ends with the exact statement of truth the rules require. This guide covers each of those parts, the formatting rules, and the newer limits on court bundles.

First, check that these rules apply to you

This guide covers the Family Court in England and Wales, which follows the Family Procedure Rules 2010 (FPR) and their practice directions. Scotland, Northern Ireland and US states have different rules, forms and wording. If your case is outside England and Wales, use your own court's guidance.

Most disputes between parents about where a child lives or how often they see the other parent are applications under the Children Act 1989. The government's court forms for these cases sit in its "Children Act forms" collection. If a template or online sample cites a different statute for an ordinary parenting dispute, be suspicious of it.

What a witness statement is

The rules define it simply. Practice Direction 22A says: "A witness statement is the equivalent of the oral evidence which the maker would, if called, give in evidence." FPR rule 22.4 describes it as a written, signed statement containing the evidence the person would be allowed to give orally, and it must be verified by a statement of truth.

Two points follow from this.

  • The statement does not replace you. Under rule 22.6(1), if a party serves a witness statement and wants to rely on it at the final hearing, that party must call the witness to give oral evidence unless the court directs otherwise. Expect to attend, and expect to be asked questions about what you wrote.
  • The judge decides what evidence counts. Rule 22.1 gives the court control over evidence, including the power to exclude evidence that would otherwise be admissible. A long statement full of side issues can do you more harm than good.

Who writes statements, and what each one is for

The parents (the applicant and the respondent, not "defendant") usually file their own statements. Other people may also give evidence, such as a grandparent who does the school run, a neighbour who saw an incident, or a friend who has seen how one parent cares for the child. Each of them writes their own statement about what they personally know.

Experts are a separate category. In children proceedings, section 13 of the Children and Families Act 2014 requires the court's permission before a party instructs an expert, before a child is assessed to produce expert evidence, and before that evidence goes before the court. Permission is given only where the evidence is "necessary to assist the court to resolve the proceedings justly". Experts give opinions within their field, not just "scientific findings". Under FPR rule 25.3, an expert's duty to the court overrides any obligation to the person who instructs or pays them. You cannot hire a psychologist and file their report on your own initiative.

Start with the official template or the formatting rules

HM Courts & Tribunals Service publishes Form C120, a witness statement template for child arrangements and parental disputes. It is a 10-page PDF, first published in November 2014 and last updated in February 2021, when the signature box was changed so the form could be sent by email. If your case fits, it is the easiest starting point.

If you write your own document, Practice Direction 22A sets the format:

  • Durable-quality A4 paper with a 3.5 cm margin.
  • Numbered paragraphs, so everyone in court can say "paragraph 14" and find the same place.
  • Pages numbered consecutively.
  • All numbers in figures, including dates.
  • In the top right-hand corner of the first page: the party the statement is made for, your initials and surname, the number of the statement (for example, whether it is your first or second), the identifying marks of any exhibits, and the date you made it.

The old advice to fit a statement on "one side of A4" is not a rule. Use as many pages as you genuinely need, within the limits below.

A plain layout looks like this:

IN THE FAMILY COURT AT [location] [Applicant] / [initials and surname] Case number: [number] Statement [1] Exhibits: [marks] Dated: [date]

IN THE MATTER OF THE CHILDREN ACT 1989 AND IN THE MATTER OF [child's name], born [date]

BETWEEN [Name] Applicant and [Name] Respondent

WITNESS STATEMENT OF [FULL NAME]

  1. I am ...
  2. ...

Statement of truth ... Signed ....................... Date ...........

The opening paragraphs: who you are and how you know things

Practice Direction 22A paragraph 4.1 requires you to give your full name, your residential address, your occupation (or a description of yourself if you have none), and whether you are a party or employed by one. Someone giving evidence in a professional capacity, such as a teacher or health visitor, gives their workplace address, position and employer instead.

Your home address may not be needed. Paragraph 4.2 says that, unless the court directs otherwise, a party to family proceedings does not have to reveal their private address or other contact details. This is the default position, so a parent does not need to ask the court before leaving their address out. This matters most where there are safety concerns. Other witnesses are not covered by that default.

Next, explain where your knowledge comes from. Paragraph 4.3 requires you to show which statements come from your own knowledge and which are information and belief, and to give the source of any information and belief. In practice:

  • "I saw the bruise on Sam's arm when I collected him on 3 June 2026." (own knowledge)
  • "Sam's teacher, [name], told me on 5 June 2026 that he had been upset at school. I believe what she told me." (information and belief, with its source)

The body: your story, in your words

Paragraph 4.1 also requires the statement to be, where practicable, in your own words and in the first person. Judges read many statements drafted in polished legal language. A clear, honest account in your normal voice is what the rules ask for.

The following practical advice is opinion, not rule:

  • Go in date order. Use a short heading for each period or topic if that helps the reader.
  • Give specifics. "On 14 February 2026 he arrived at 9 pm, two hours late" is evidence. "He is always unreliable" is a judgment.
  • Keep the child at the centre. Explain what each event meant for the child, not just how it affected you.
  • Admit what you don't know and what you got wrong. A statement that never concedes anything is harder to believe.
  • Leave out insults and rumour. If you cannot say how you know something, think hard before including it.

If you are alleging domestic abuse, Practice Direction 12J governs how the court deals with it in private law children cases. The court should decide early whether a separate fact-finding hearing is needed, and the person who asserts a fact must prove it. The Domestic Abuse Act 2021 defines abusive behaviour broadly, including coercive control. In Re H-N [2021] EWCA Civ 448, the Court of Appeal held that PD 12J remains fit for purpose. It is worth setting out each incident with its date, what happened, and who else saw it or was told, because the court may need to decide each allegation on the evidence.

Watch the length. Under the revised court-bundle practice direction (PD 27A), which came into force on 2 March 2026, a witness statement is reported to be limited to 25 pages excluding exhibits, though the court can allow more. Check the current text of PD 27A or ask the court office before you rely on that figure.

Exhibits: how to attach your evidence

Documents you rely on, such as school reports, medical letters or a contact schedule, become exhibits. Practice Direction 22A sets out how to handle them:

  • In the statement, introduce each one with the words "there is now shown to me marked …" followed by its mark.
  • Keep exhibits separate from the statement itself, not bound into its pages (paragraph 9.1(a)).
  • Put the same top-right markings as the statement on the first page of each exhibit, plus that exhibit's mark (paragraph 9.3).
  • If one exhibit contains several documents, put a list at the front showing each document and its date.
  • Number exhibits consecutively across all your statements in the case. If your first statement ended at your fifth exhibit, your second statement starts at the sixth.

Be careful with messages and photos. Under the revised PD 27A, emails, texts, WhatsApp and social media messages, voice notes, recordings and photographs are excluded from the court bundle unless the court gives permission. If your case depends on messages, ask the court how to put them forward instead of assuming you can add them.

The statement of truth: use the exact words

Every statement must end with a statement of truth. Practice Direction 22A paragraph 6.4 prescribes the wording:

> "I believe that the facts stated in this witness statement are true."

It must also be accompanied by a warning that proceedings for contempt of court may be brought against anyone 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. Form C120 includes this wording. If you write your own statement, copy the wording from the practice direction. Phrases such as "true to the best of my knowledge" are not the prescribed form.

Then sign it, print your name and date it. Missing the signature or the statement of truth has real consequences. In a 2025 Family Court judgment, a mother's statement was treated as not complying with rule 22.4 because it was unsigned and lacked the statement of truth.

What happens if you lie. FPR rule 17.6 says contempt proceedings for a false statement can be brought only by the Attorney General or with the court's permission, so they are not automatic. Contempt is serious, though. Section 14 of the Contempt of Court Act 1981 sets a maximum committal term of two years.

Filing it and getting it to the hearing

Who must file statements, and by when, depends on the directions the court makes in your case. Rule 22.5 lets the court give directions about serving statements on the other parties. Read your order carefully, keep to its deadline, and send the statement to everyone the order names.

Before a hearing, the parties' documents are gathered into a court bundle. According to practitioner summaries of the March 2026 changes to PD 27A, the main rules are:

  • Electronic bundles are now the norm, as a single PDF of up to 350 pages.
  • The parties must agree the bundle contents at least 7 working days before the hearing.
  • The bundle must be filed and served at least 5 working days before the hearing.
  • Position statements are limited to 3 pages.

PD 27A was amended again later in March 2026, so check the version in force on the date of your hearing.

A final checklist

  • Is your case in England and Wales, and does the header cite the right Act (usually the Children Act 1989)?
  • A4, 3.5 cm margin, numbered paragraphs and pages, numbers in figures?
  • Top-right corner: party, your initials and surname, statement number, exhibit marks, date?
  • Name, occupation and (unless you are a party choosing to withhold it) address in the opening?
  • Own knowledge clearly separated from information and belief, with sources given?
  • Written in your own words, in the first person and in date order?
  • Exhibits introduced with "there is now shown to me marked …", kept separate, and numbered consecutively?
  • Within the page limit, or permission obtained to exceed it?
  • Exact statement of truth and contempt warning included, signed and dated?
  • Filed and served by the date in your court order?
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