Jurisdiction(s):
United Kingdom

Trial witness statements: practitioner guidance on content, credibility and CPR compliance (PD 57AC, PD 32, PD 57AB; England and Wales)

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Practice notes

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This guide sets out key principles for a witness when preparing a clear and credible witness statement that stands the best chance of not being weakened in cross‑examination. For this guidance, it is assumed the witness drafts their own statement, with input from the lawyer whose client is seeking the witness’s evidence to indicate the matters the statement should address.

The purpose of a witness statement

A witness statement, supplied to all other parties and the court well in advance of the start of a trial, usually serves as the evidence in chief that the witness would give if examined orally. It is therefore the written counterpart to the witness’s answers to non‑leading questions. This is a critical point for a witness to keep in mind throughout the drafting process.

A witness statement is not:

an exposition of the legal case or the defence to a claim that the party calling the witness is advancing
a narrative account of the background to, and what occurred during, the matters at the heart of the dispute
a commentary on important documents...

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Web page updated on 22/05/2026

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