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This Checklist explains the layout a skeleton argument ought to adopt and gives an overview of material required, together with practical considerations to bear in mind. Read it with Practice Note: Skeleton arguments. Details of a skeleton’s structure and substance will also vary depending on the court in which the claim is progressing, and local requirements should be checked. For more detail, see Practice Note: Skeleton arguments—Court specific guidance. The CPR include guidance on skeleton arguments intended for use in appeals; however, that guidance is of general assistance and not confined solely to appeal work. For those provisions, please consult the Practice Note: Skeleton Arguments in an appeal—general provisions. Structure Content Example/ practical points to consider Heading State what the document comprises and identify the party you represent. If there is more than one skeleton argument in the proceedings—for example, where skeletons were filed for earlier applications—ensure you distinguish between them by clearly identifying the specific hearing for which...
This Checklist sets out a recommended approach for dealing with and responding to a freezing injunction. It serves as a starting point, highlighting the key issues you should consider when preparing your response. It is assumed that: the freezing injunction was made pre-action and without notice; and your client is the defendant in the underlying substantive claim For further guidance on freezing injunctions generally, see the following Practice Notes: Freezing injunctions—guiding principles Freezing injunctions—the application Freezing injunctions—the draft order Ensuring you have all the necessary documentation The applicant should have provided, at the very least, the following documents: the application notice the affidavit(s) in support the sealed order a transcript of the hearing the skeleton argument (if one was used at the hearing) If any of the above are missing, request them from the applicant’s solicitors as a matter of urgency. You will need...
This Practice Note explores the steps taken by an inexperienced advocate when preparing a skeleton argument in advance of a hearing in civil proceedings. It sets out the general requirements for this crucial document and highlights court‑specific guidance. It also considers who should review the draft before the skeleton argument is lodged at court. What is a skeleton argument? A ‘skeleton argument’ (referred to in this Practice Note as the ‘skeleton’) is written advocacy preceding and supporting oral submissions. As the label suggests, its role is to map out the arguments an advocate for a party intends to advance on the issues for decision at the hearing to which the skeleton relates. It is not a full treatment of every contention, nor a vehicle for extensive detail about the party’s case. Ordinarily, it will identify the issues, provide limited background sufficient for swift understanding, state the propositions the party filing the skeleton will ask the court to accept at the hearing, indicate the evidence by which those propositions...
Applications in the King’s Bench Division If your case is before the King’s Bench Division (KBD), the provisions of the King’s Bench Guide apply to any application you pursue. This Practice Note gives guidance on applications in the KBD, cross‑referring to the relevant sections of the King’s Bench Guide. Its focus is preparation for an application hearing in the KBD, particularly the documents that must be ready in advance, and the method and timing for lodging them with the court. For guidance on other aspects of the KBD applications process, see these Practice Notes: Making an application in the King’s Bench Division (KBD) Determination of applications in the King’s Bench Division (KBD) The following general points should be noted: The King’s Bench Guide provides practical detail on KBD procedure but does not replace the CPR and must be read in conjunction with those rules (King’s Bench Guide, para 1.2). Alongside this Practice Note, you should also familiarise...
This Practice Note sets out how a respondent files an Answer to an appeal, together with the possibility of advancing a cross-appeal. It also outlines the consequences of not providing a respondent's Answer to an appeal, the time limits for lodging an Answer and/or cross-appeal, and the method for seeking extensions of those limits. It addresses the position where, at the full hearing, a respondent wishes to contend that the Notice of Appeal raises a point of law not pursued in the employment tribunal, and it explains the process by which an appellant may serve a Reply to a cross-appeal... The EAT will send to all parties who are respondents to the appeal: the Notice of Appeal, with any amendments which have been permitted any submissions or skeleton argument lodged by the appellant Within 28 days of the seal date of the order, unless another period is directed, each respondent must present a respondent's Answer, including any cross-appeal if it is to...
Appeal No. HU/1234/2025 IN THE FIRST-TIER TRIBUNAL IMMIGRATION AND ASYLUM CHAMBER Between: MAGGIE SMITH (Appellant) – and – Secretary of State for the Home Department (Respondent) APPEAL SKELETON ARGUMENT Mrs Maggie Smith (“the Appellant”) challenges the decision recorded in the Respondent’s Reasons for Refusal Letter (“the RFRL”) dated 14 February 2025. The appeal is brought under section 82(1)(b) of the Nationality, Immigration and Asylum Act 2002 against the refusal of her human rights claim, asserting that removal would be unlawful pursuant to section 6 of the Human Rights Act 1998, as it would represent a disproportionate interference with Article 8 ECHR. FACTUAL SUMMARY The Appellant is a French national, born on 18 January 2000. She is married to Bernie Smith, a British national, born on 14 February 1999. They met in the United Kingdom and married in the United Kingdom on 1 January 2024. The Appellant entered the United Kingdom in 2019 with a student...