Bundles - How to Create an Application Bundle

What is an Application Bundle?

An application is a request for a procedural order (e.g. for permission to use an expert witness) or for temporary relief (e.g. an injunction preserving the status quo on the ground until trial). The person applying for an injunction lodges with the court office an Application Notice, a draft order - setting out what order they would like the court to make - and a witness statement(s) which will refer to several documents (or small groups of related documents) identified as exhibits (with each exhibit having a front sheet before the document identifying which exhibit number it is). The party responding to the application may or may not file/serve witness statement(s) and exhibits in response, and the party applying will sometimes file/serve a further witness statement (and possibility further exhibits) in response to that. Unlike a trial, which will typically take a number of days and which is the culmination of the whole litigation process, which takes many months, an application hearing normally last no more than 2 hours and it is often only a week between the applicant issuing an Application Notice, with draft order, witness statement and exhibits, and the hearing taking place, with the other party's (Respondent's) witness statement (and any exhibits) being lodged perhaps only two days before the hearing of the application. If there are very few pages some courts may be prepared to simply use the loose witness statements, exhibits, Application Notice and draft order, but usually the court will require an Application Bundle to be produced by one of the parties. In an Application Bundle every page has a page number and the judge and each party at the hearing have identical copies of the Bundle.  

The pages in an application bundle are numbered within section - i.e. the pages in the first section are numbered A1, A2, A3, etc, and the pages in the second section are numbered B1, B2, B3, etc. This means that if documents need to be inserted late into the Respondent's witness statement and exhibits section the page numbering of other sections will not be affected. 

The Application Bundle will have an Index at the front. Despite its name, the Index is not like the index of an ordinary book. An ordinary non-fiction book will have a table of contents at the front listing each section or chapter in the order it appears with the page number, and there will also be an index at the back listing alphabetically people, places, topics etc. with the page number where that person, place, or topic is referred to in the book. The Index of a Application Bundle is not at all like an alphabetic index that you find at the end of a typical book. It is at the front and is really a table of contents but much more detailed than the average table of contents in a book. Why is it called an Index? The word Index is actually an old word for a table of contents, rarely used in this sense now outside the legal context, but this is still its primary meaning when used by lawyers and judges.

An Application Bundle will typically be arranged with the sections in the following order:

Index. This will list, with page numbers, each document in the bundle. 

A - Application Notice & Draft Order 

B - Chronology. This is a list, with dates, of the main events relevant to the Application. This is not always needed but, depending on the nature of the Application and when it is made, this could be procedural events (when the litigation was started, when various orders were made by the court, when the Application Notice was issued, etc.) or it could be central facts in the case such as when the actions such as trespass to land, starting building work, start of a rival business by former employees etc., against which an injunction is sought, took place. Or it may be a combination of both procedural events and facts on the ground.      

C - Applicant's witness statement and exhibits

D - Respondent's witness statement and exhibits

E - Costs Statements

Generally the Respondent's witness statement and exhibits section will always be included even if, at the time the application bundle is produced, there is nothing to go in this section. This is because applications are often urgent, with the Respondent only being given short notice (e.g. 3 days) of the hearing and the Respondent may file and serve a witness statement relatively late. If the section Respondent's witness statement and exhibits is included from the outset as an empty section, late documents can, if appropriate, be inserted into it without changing the sections letters (and page numbers) of subsequent sections, and at least the Respondent's witness statement and exhibits section will be mentioned in the Index even if no documents are listed. 

Creating the Application Bundle PDF

The basic method is that you store each PDF to be included in the bundle on your computer with a appropriate descriptive name which is suitable for use in an Index such as:-

Application Notice
Draft Order
Witness Statement - John Smith
Exhibit JKS1 - Photographs
Exhibit JKS2 - Correspondence
Exhibit JKS3 - Accounts

and then load the PDFs into CaseLines DCS. Click the Download Complete Bundle button as shown below to download the Bundle as a PDF. Check that all pages (except the initial Front Page and Index) have red page numbers at the bottom right.

You will be printing one section at a time (when printing double-sided you print one section at a time in order to ensure that the first page of each section is printed recto). You can do this by printing ranges of pages from the Complete Bundle PDF but most people find it easier to download the individual section PDFs and use those to print from.

Printing out and assembling the Bundle



The information on this page about specific computer techniques is provided for information purposes only. Every reasonable effort has been made to ensure that the information is accurate and up to date at the time it was written but no responsibility for its accuracy, or for any consequences of relying on it, is assumed by me. You should satisfy yourself, before using any of the techniques, software or services described, that the techniques are appropriate for your purposes and that the software or service is reliable.

There is some variation between the procedural requirements of different tribunals and courts for different types of case. The above explanation of procedural rules relating to bundles is only an overview and in order to be reasonably concise I have had to leave some details out - details which are likely to affect what the procedural law would say about your own situation. So please do not rely on the above but contact me for advice.

This page was lasted updated in July 2018. Disclaimer