Feb 2 • Templates & Checklists
📄 How to Paginate and Reference Documents Properly (Litigants in Person – England & Wales)
Why pagination matters more than you think
Pagination is not cosmetic. It is how the court navigates your case.
If a judge cannot quickly find what you are referring to, one of three things happens:
- the point is missed
- the hearing is slowed
- your credibility drops
Good pagination makes you easier to deal with. That matters.
What pagination actually means
Pagination means numbering every page of the bundle in a clear, consistent way, so that everyone in the hearing is literally on the same page.
It is not:
- numbering each document separately
- restarting page numbers without explanation
- relying on PDF thumbnails
The two acceptable pagination methods
Unless the court directs otherwise, you should use one of the following:
âś… Method 1: Continuous pagination (most common)
The entire bundle is numbered sequentially:
- Page 1
- Page 2
- Page 3
- etc.
This is simple and usually preferred for smaller bundles.
âś… Method 2: Section-based pagination
Each section has its own letter and numbering:
- A1, A2, A3
- B1, B2, B3
- C1, C2, C3
This works well for larger or more complex bundles and aligns neatly with a bundle index.
Pick one method and stick to it
Do not mix methods.
Do not:
- use page numbers in one document
- exhibit numbers in another
- and PDF auto-numbering on top
Inconsistency creates confusion very quickly.
How to paginate in practice (simple approach)
If you are creating the bundle yourself:
- Combine documents into one PDF (if directed)
- Decide on your pagination method
- Add page numbers before filing
- Check that the numbers:
Always open the final PDF and scroll through it before sending.
How to reference documents correctly in writing
When referring to documents in:
- a position statement
- a hearing
- written submissions
You should reference them like this:
“As shown in the chronology at page E3…”“This is addressed in the Applicant’s statement at paragraph 12, page C5.”“The email dated 14 March 2024 appears at page F12.”
This tells the judge:
- what the document is
- where it is
- why it matters
Vague references (“see my evidence”) are ineffective.
Referencing paragraphs vs pages
Use:
- paragraph numbers when referring to statements
- page numbers when referring to the bundle
Example:
“Paragraph 18 of my statement (page C7) explains this.”
This is clear and professional.
Common pagination mistakes (avoid these)
- Page numbers that don’t match the index
- Referencing documents that aren’t in the bundle
- Saying “see screenshot attached” without a page reference
- Changing the bundle after pagination without updating numbers
- Assuming the judge will “find it”
Judges do not have time to search.
If the other party prepared the bundle
You should still:
- check the pagination
- note any errors
- politely raise serious problems early
If you are speaking in court, use the pagination as provided, even if it’s poor. Do not invent your own references.
The golden rule
Every reference you make should allow the judge to locate the document within seconds.
If you help the court, the court is more likely to help you.
Where this fits in your preparation
Pagination sits alongside:
- a clear bundle index
- a focused position statement
- restrained, relevant evidence
Together, these signal organisation, reliability, and respect for the court’s time.
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📄 How to Paginate and Reference Documents Properly (Litigants in Person – England & Wales)
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