How do I prepare a witness statement for court?

Introduction

A witness statement provides the court with a factual account from a person who knows the events in dispute. In family proceedings in England and Wales witness statements carry weight because judges rely on them to assess credibility, chronology and factual detail. Clear, honest and well structured statements help the court and improve a party’s case.

Understand the purpose

A witness statement sets out facts the witness can personally attest to. It is not a document for argument or legal submissions. Witnesses should stick to what they saw, heard or did, and avoid repeating legal conclusions or hearsay unless necessary and identified as such.

Structure and layout

Follow a simple, consistent structure to make the statement easy to read:

– title and court details: include the court, case number and parties’ names

– witness identity: state full name, age, address and relationship to the parties

– statement purpose: say why the witness gives evidence and what matters the statement covers

– chronology: provide a short timeline of key events before the detailed account

– numbered paragraphs: present each point in a separate numbered paragraph for easy reference

– signature and statement of truth: end with a signed statement of truth in the format required by the Family Procedure Rules

Be factual and precise

Witnesses should report facts clearly and avoid speculation. Use dates, times, locations and names where possible. If a witness cannot recall exact details they should say so rather than guessing. Where a document supports an assertion refer to it and add it as an exhibit with a clear label.

Deal with documents and exhibits

When the witness refers to documents they should identify them precisely. Use exhibit labels such as “Exhibit A” and attach copies in the order mentioned. State how the witness obtained the document and why it matters. Do not attach unnecessary material that does not support the witness’s account.

Avoid legal argument and opinion

Witness statements focus on facts. If the witness has expert knowledge, the court needs that evidence from a qualified expert rather than from a lay witness. Where a witness gives an opinion it should be limited, clearly identified as opinion and supported by the facts on which it rests.

Be honest about limitations and hearsay

If the witness relies on what someone else told them they must identify it as hearsay and state the source. The rules allow hearsay in certain circumstances but the court must know its origin. If the witness was not present at an event they should not pretend otherwise.

Keep language plain and concise

Use plain English short sentences and active verbs. Avoid jargon, emotional language or rhetorical flourishes. Judges read many statements; clarity and brevity improve comprehension and credibility.

Check format and procedural requirements

Follow court directions about font size, pagination and bundle numbering. Ensure the statement contains the required statement of truth and is signed and dated. If the statement will be used in a remote hearing provide an electronic copy in the court’s preferred format.

Review and professional support

Before signing the witness should review the statement carefully and ask the solicitor to check for clarity and relevance. Solicitors can help frame the evidence and ensure it fits the overall case strategy while preserving the witness’s voice.

Conclusion

A well prepared witness statement aids the court and strengthens a party’s case. Present facts clearly, attach relevant exhibits, avoid legal argument and sign the required statement of truth. For contested or complex matters the guidance of an experienced family solicitor helps ensure the statement meets procedural standards and supports sensible case strategy.

At Alexander JLO we have many years of experience of dealing with all aspects of family law and will be happy to discuss your case in a free no obligation consultation. Why not call us on +44 (0)20 7537 7000, email us at info@london-law.co.uk or get in touch via the contact us button and see what we can do for you?

This blog was prepared by Peter Johnson on 1st December 2025 and is correct at the time of going to press. With over forty years of experience in almost all areas of law Peter is happy to assist with any legal issue that you have. He is widely regarded as one of London’s leading divorce lawyers. His profile on the independent Review Solicitor website can be found Here.

To follow up on any of the above please contact Guy Wilton of our family department. Guy has wide experience of acting for the firm’s clients, their family and their businesses. Guy’s experience as a lawyer started in the Northern and Welsh Circuits, including the Liverpool Courts, where he represented numerous clients after being called to the Bar, before opting to join Alexander JLO in 2017 and qualifying as a solicitor in 2024. He is a highly experienced family lawyer with a particular interest in financial remedy proceedings and child contact disputes.

Guy’s profile on the independent Review Solicitor website can be viewed here.