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Skeleton arguments in civil litigation: practitioner checklist on structure, content, timing and authorities (England and Wales)

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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 document is intended to be used at the outset.

For example: Skeleton argument on behalf of the Defendant for the hearing on [insert date]...

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Web page updated on 20/05/2026

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