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This Practice Note provides general guidance for drafting witness statements of fact under CPR Part 32 in civil proceedings. In particular, it deals with what should be covered in witness statements and the courts’ approach to them, using the witness’ own words (para 18.1 of Practice Direction 32), how to ensure consistency with other witness statements and how to refer to other documents exhibited to witness statements. It also covers the issue of expert evidence in factual witness statements and the Admissibility of such evidence said to be of an expert nature.

This Practice Note provides guidance on the interpretation and application of the relevant provisions of the CPR. Depending on the court in which your matter is proceeding, you may also need to be mindful of additional provisions—see further Court specific guidance below.

It should be read in conjunction with:

1. •

   Practice Notes:

   1. â—¦

      Planning witness evidence and choosing witnesses

   2. â—¦

      Drafting witness statements—technical Requirements—which includes guidance on matters such as how to format the witness statement, the required wording to be used and the statement of