How I Prepare a Specific Issue Order Application: Step by Step for Clients

If you face a single contested question about your child and the process feels daunting this guide explains exactly how I prepare a Specific Issue Order application on your behalf. I write from practical experience in family law in England and Wales and set out the steps I take, the paperwork I use, the evidence I gather and the tactical choices I make to give your case the best chance of success while keeping costs proportionate.

Overview: what a Specific Issue Order does

A Specific Issue Order resolves one discrete question about a child’s upbringing under the Children Act 1989. Typical issues include which school the child should attend whether the child may travel abroad whether a passport should be issued or whether a particular medical treatment should proceed. The court decides according to the welfare principle and the statutory welfare checklist. My role is to frame the dispute so the court can focus on the child’s best interests.

Initial client meeting and case assessment

1. Establish the precise issue

I begin by asking you to describe the specific decision you want the court to make. Precision matters. Vague requests slow the process and risk the court declining to grant relief. I will help you frame the application so it asks for a clear specific order that the court can implement.

2. Review parental responsibility and standing

I check who holds parental responsibility and whether anyone else has standing to apply such as a person the child lives with or a local authority. If standing is uncertain I advise on whether an application is likely to be accepted and whether the court should be asked to decide on parental responsibility as part of the case.

3. Assess urgency and the need for interim relief

If the matter is time sensitive I determine whether to apply for interim orders. Examples include imminent travel medical appointments or school admission deadlines. I gather evidence to justify urgency and seek an expedited hearing where necessary.

4. Explore alternatives to court

Before we file I discuss mediation negotiation and other dispute resolution options. The court expects reasonable attempts at alternative dispute resolution and in most cases you must attend a Mediation Information Assessment Meeting unless safety concerns exist. If mediation appears realistic I help you arrange it and, if needed, prepare a mediation certificate for the court.

Documentary preparation: building a clear evidence bundle

1. Chronology

I prepare a concise chronological timeline that pinpoints events relevant to the dispute. Judges appreciate a short clear chronology that sets out dates attempts to resolve the matter and turning points.

2. Core documents

I assemble essential documents such as:

– school reports and admission correspondence

– medical letters and clinical assessments

– previous court orders consent orders or parenting plans

– passports travel itineraries or booking confirmations when travel is contested

– correspondence between the parties about the specific issue

3. Evidence schedule

I create an evidence schedule that lists every document and explains its relevance. This helps the judge and Cafcass quickly identify material that supports your position.

4. Witness statements

I draft witness statements for you and other relevant witnesses such as teachers health professionals or carers. Statements must be factual, concise and focused on the child’s welfare. I advise witnesses on how to present factual observations not opinion.

5. Expert reports when necessary

Where specialist input matters, for example medical ethics psychiatric assessments or education experts, I instruct or help obtain appropriate reports. I explain the scope of such reports and how they will be used in court.

Preparing the application: completing Form C100 and supporting bundles

1. Drafting Form C100

I draft Form C100 carefully so it precisely identifies the order sought and the reasons. The form must clearly explain how the issue affects the child’s welfare and list prior attempts to resolve the dispute. I ensure the remedy sought is proportionate and specific.

2. Statement of facts and parenting proposals

I prepare a short witness statement or position statement that sets out the facts in a logical order and explains the practical relief requested. Where appropriate I propose a realistic practical solution the court can adopt immediately.

3. Bundles and index

I prepare a court bundle with an index, table of contents and paginated documents. A well-ordered bundle makes hearings more efficient and reduces fees. I include the chronology evidence schedule and witness statements at the front so the judge and Cafcass can read them first.

Mediation and the MIAM requirement

I explain the Mediation Information Assessment Meeting requirement and whether an exemption applies. If you attend mediation I help document attempts at settlement and prepare a Mediation Certificate if mediation concludes. If there are safety concerns or mediation is inappropriate I set out clear reasons and supporting evidence for the court.

Working with Cafcass and guardians

If Cafcass becomes involved I liaise with the officer and explain the evidence they need. I prepare you for Cafcass assessments and ensure Cafcass has access to the bundle and witness statements. I encourage open constructive engagement because Cafcass recommendations carry weight with the court.

Interim hearings: securing temporary protection

If urgent interim relief is required I prepare an application for a first hearing and gather concise evidence to support temporary orders. Interim hearings require clarity and focus. I present only what the judge needs to make a quick practical decision and protect the child pending any final hearing.

Managing disclosure and dealing with allegations

I manage the disclosure process to avoid surprise allegations. If allegations arise I advise on how to address them promptly and appropriately. I ensure your statements address concerns directly and provide supporting evidence where available. Late unsupported allegations damage credibility in court.

Costs planning and funding options

I give clear costs estimates based on a staged approach: initial advice drafting Form C100 preparation of a bundle and representation at interim and final hearings. Legal aid is limited in private family law so I explain eligibility criteria where safeguarding or domestic violence concerns exist. We do not deal with legal aid. I also offer fixed fee or limited scope options where appropriate to control costs.

Preparing you for court: practical advice for hearings

1. What to expect at the hearing

I explain how the hearing runs who will speak and the likely questions the judge will ask. I prepare you to give clear concise answers and to focus on the child’s welfare not adult grievances.

2. Trial readiness

I help you organise documents and rehearse witness evidence. I advise on courtroom etiquette and on how to behave if the other party acts provocatively. Judges place value on calm constructive behaviour.

3. Orders and drafting

If the judge grants a Specific Issue Order I ensure the wording is precise to avoid future disputes. I draft proposed order wording ahead of the hearing and negotiate amendments where necessary. Clear drafting reduces risk of enforcement applications later.

Enforcement and variation after the order

I advise on steps to enforce an order if the other party breaches it. Remedies range from enforcement directions to fines and in extreme cases committal proceedings. If circumstances change I prepare applications to vary the order with supporting evidence that demonstrates why change is necessary.

Common mistakes I avoid when preparing an application

– Overloading the court with irrelevant documents — I keep bundles focused on what matters for the decision.

– Emotional narrative rather than objective evidence — I prioritise factual statements and professional assessments.

– Failing to demonstrate attempts at resolution — I record mediation efforts and negotiation attempts clearly.

– Asking for broad remedies — I ask for precise specific relief the court can implement.

Checklist: what I will ask you to provide

– a clear chronology of events with dates

– copies of school reports medical letters and any previous court orders

– copies of relevant correspondence and proposals between the parties

– names and contact details of potential witnesses

– any Mediation Certificate or record of mediation attempts

Final thoughts: practical, proportionate, child-focused

When I prepare a Specific Issue Order application I focus on practical proportionate steps that protect the child while controlling legal cost and delay. I frame the dispute tightly assemble clear evidence and present a straightforward case to the court and Cafcass. That approach increases the chance of a timely effective resolution that the child and family can follow.

If you find the process confusing or overwhelming contact me, Peter Johnson of Alexander JLO Solicitors. I will review the facts advise on next steps and, if appropriate, prepare and present the Specific Issue application so you can focus on the child rather than on legal procedure.

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 Alexander JLO’s senior partner, Peter Johnson on 25th November 2025 and is correct at the time of publication. With decades 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