Bundles - Inserting numbered dividers in hardcopy bundles

The reason for inserting numbered tabs

The essential requirements of a court/tribunal bundle are that each page should be numbered and there should be an "index" (i.e. table of contents and/or PDF bookmarks) giving the name and date of each document and enabling it to be quickly located within the bundle.

In an eBundle each document has a PDF bookmark and the person using the ebundle can go to document simply by tapping on the relevant bookmark. Alternatively they can go to any page in the bundle simply by typing in the page number.  

The page numbers in a bundle are essential so that everyone at the hearing - judge, witnesses, and barristers - can be sure they are looking at the same page. A barrister may ask a witness to, for example, to go to page 462, and then ask the witness a question about the document at page 462. The page number enables the judge and the other barristers to also go to the same page in their copies of the bundle.

If a hardcopy bundle is being used, a barrister may say to a witness "please open volume 1 in front of you, and turn to page 462" but it can take a witness a little time to find page 462. Most people, when looking for a page number will open the volume where they guess the page number might be. That might turn out to be, say, page 403. They will then estimate what thickness of pages to turn over, ending up at, say, page 439, and so on, until they are near the page number they are seeking when they will probably start to turn over a page or a couple of pages at a time until page 462 is reached. This is done instinctively but it can take a little time and make it more difficult for witnesses to concentrate on the question they are being asked. 

To assist everyone, dividers are placed at intervals in the hardcopy bundle. A typical bundle is divided in to a handful of sections A, B, C, D, E etc. and so dividers labelled A, B, C, D, E, etc. are inserted at the beginning of each section. The Barrister can then say to a witness "please open volume 1 in front of you, go to tab D and find page 462" which will take the witness less time.

A typical hearing bundle will consist of only a couple of volumes but in a minority of cases there are many volumes and a whole volume may be only a single section - or a single section might even extend over several volumes. In this case it is useful if, in addition to inserting lettered dividers at the start of each section, numbered dividers are inserted at intervals, say after every 40 pages.  It does not have to be exactly every 40 pages - and you should avoid inserting a divider in the middle of a document - but it is, of course, essential that the numbered dividers are inserted in exactly the same position in every hardcopy of the bundle - e.g. if tab 42 is immediately before page 1549 in the hardcopy of the bundle in the witness box, then tab 42 must be immediately before page 1549 in all other hardcopies of the bundle - i.e. the hardcopies used by the judge and by counsel.


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 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 rules 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 April 2020. Disclaimer