📄 Position Statement Template (Litigants in Person) England & Wales – Private Family Law

Purpose: A position statement is a short document to help the judge understand what this hearing is for, what you are asking the court to do today, and what the real issues are.It is not your life story. It is not a replacement for evidence.

🔹 HOW TO USE THIS TEMPLATE (READ FIRST)

Keep it 1–2 pages (3 only if unavoidable)
Use plain, neutral language
Number your paragraphs
File and serve it in accordance with the court’s directions
Replace all bracketed text with your own details

If you cannot explain something clearly in writing, the court will struggle to deal with it orally.

POSITION STATEMENT

Case details

Court: [Name of Family Court] Case number: [e.g. AB12C345] Hearing date: [DD/MM/YYYY] Type of hearing: [e.g. First Hearing / Review / Fact-finding / Final Hearing]

Applicant: [Your initials only if filing publicly]Respondent: [Other party’s initials only]

Children:

[Child A – year of birth]
[Child B – year of birth]

Purpose of today’s hearing

This is a [type of hearing].
The purpose of today’s hearing is for the court to:

(Be precise. Avoid “to resolve everything”.)

Orders / directions sought today

The Applicant/Respondent respectfully seeks the following orders or directions today:
These are sought because:

What is agreed

The following matters are agreed between the parties (if any):

(If nothing is agreed, state: “There are currently no agreed issues.”)

What is in dispute

The key issues in dispute for the court’s consideration are:
These issues are relevant because they relate to:

Safeguarding / welfare summary (if relevant)

The Applicant/Respondent summarises safeguarding or welfare concerns as follows:
These concerns are said to impact the children because:

(Avoid emotional language. Avoid diagnosis. Stick to observable facts.)

Evidence relied upon (brief)

The Applicant/Respondent relies on the following key documents:

[e.g. Chronology dated DD/MM/YYYY]
[e.g. Statement of [name] dated DD/MM/YYYY]
[e.g. Cafcass letter/report dated DD/MM/YYYY]

(Do not list every exhibit. Highlight what matters.)

Compliance with previous directions

The Applicant/Respondent confirms that they have:

complied with the court’s directions dated [DD/MM/YYYY], or
explains briefly any non-compliance and the reason for it.

Next steps sought (if not concluded today)

If the matter cannot be concluded today, the Applicant/Respondent respectfully invites the court to consider:

[e.g. listing a further hearing]
[e.g. directing statements / reports]
[e.g. timetabling steps to final resolution]

Statement of position

This position statement is filed to assist the court with case management and clarity.
The Applicant/Respondent is a litigant in person and has sought to present this position succinctly and proportionately.

Signed: ___________________________Name: [Your name]

Date: [DD/MM/YYYY]

⚠️ COMMON MISTAKES TO AVOID (IMPORTANT)