A skeleton argument is a concise written document prepared by a party (or their legal representative) and submitted to the court in advance of a hearing. It summarises the key factual and legal issues in dispute, sets out the main arguments that will be advanced, and identifies the authorities (cases, statutes, or other materials) that will be relied upon.
It acts as a “roadmap” for the judge and the advocate, helping to focus oral submissions and save valuable court time. Skeleton arguments (or their equivalent, such as position statements) are now a standard feature of litigation in England and Wales.
Purpose and Benefits of a Skeleton Argument
The primary purpose of a skeleton argument is to assist the court by clearly and concisely setting out the arguments on which a party intends to rely. A well-drafted skeleton:
- Defines and narrows the real issues in dispute
- Allows the judge to pre-read the case efficiently
- Provides a clear structure for oral advocacy
- Promotes efficiency in hearings
Judges frequently read skeletons before the hearing. A strong, well-structured skeleton can significantly influence the outcome by framing the case in advance.
Skeleton arguments are generally not required in the Magistrates’ Court unless the court specifically directs for one (e.g. for a complex legal issue).
Skeleton Arguments in Civil Proceedings (CPR)
In civil cases, skeleton arguments are governed by the Civil Procedure Rules 1998 (CPR) and the associated Practice Directions. The most important guidance is contained in Practice Direction 52A (Appeals), Section V, which sets out the requirements for skeleton arguments and is widely followed as best practice in first-instance hearings as well.
Key requirements include:
- Must be concise, clear and focused
- Set out in numbered paragraphs
- Clearly define the areas of controversy
- Contain cross-references to the relevant documents in the court bundle
- Be self-contained (no incorporation by reference to earlier documents)
- For each authority cited, state the proposition of law it supports and give specific page or paragraph references
- Avoid lengthy quotations from cases or documents
Failure to comply with these requirements may result in costs sanctions or adverse comments from the court.
Skeleton Arguments in Criminal Proceedings (CrimPR)
In criminal cases, skeleton arguments are governed by the Criminal Procedure Rules 2025 (CrimPR) and the Criminal Practice Directions 2023 (as amended Nov 2025).
They are commonly required in the Crown Court for contested applications, trials involving significant legal argument, complex sentence hearings, and all appeals to the Court of Appeal (Criminal Division).
Key requirements include:
- Strong emphasis on brevity and clarity
- Must clearly identify the real issues
- Proper citation of authorities (proposition of law + pinpoint reference)
- Must comply with any page limits or other directions set by the court
- Must be filed and served in accordance with any timetable set by the court
Non-compliance may lead to the skeleton being rejected, costs orders, or adjournment of the hearing.
Skeleton Arguments in Family Proceedings (FPR)
In family law cases, the Family Procedure Rules 2010 (FPR) and Practice Direction 27A (Court Bundles and Position Statements) apply. The terminology differs slightly from civil and criminal litigation.
In financial remedy proceedings, the term “position statement” is commonly used, and this includes what would otherwise be a skeleton argument. Strict page limits apply:
- First Appointment: maximum 6 pages
- Other interim hearings: maximum 8 pages
- FDR appointment: maximum 12 pages
- Final hearing: maximum 15 pages (excluding agreed documents)
In children and other non-financial family cases, a separate skeleton argument may be filed where appropriate (generally not exceeding 20 pages).
For appeals in family proceedings, see FPR PD 30A, which requires a skeleton argument to accompany or follow the appellant’s notice.
Common requirements across family cases include:
- Numbered paragraphs
- Cross-references to the court bundle
- Clear propositions of law for each authority cited
- No new evidence or factual allegations
- Emphasis on the welfare of the child (where relevant) or the s.25 factors in financial cases
Recommended Structure for a Skeleton Argument / Position Statement
- Introduction – The order or relief sought and the party’s position
- The Issues – A clear numbered list of the matters the court must decide
- Factual Background – Short neutral chronology or agreed facts
- Legal Framework – Relevant statutes and case law
- Submissions – Arguments on each issue, clearly linked to the facts and law
- Conclusion – Summary of the relief requested
Published Skeleton Argument Templates and Examples
Several official and professional templates are publicly available:
- Official GOV.UK Template – Form AC014 (Skeleton Argument) – ideal for appeals and tribunals
- SRA Guidance Template
- Many barristers’ chambers and law firms publish precedent skeletons for specific applications (e.g. summary judgment, interim injunctions, family financial remedies)
While using a template is helpful, always tailor it to the specific requirements of your court, hearing type and any individual directions from the judge.
Best Practice Tips
- Use short sentences, clear headings, and numbered paragraphs
- Use 12-point font with 1.5 line spacing
- Avoid footnotes where possible
- File and exchange by the court deadline (usually the day before the hearing)
- Always comply with any specific directions from the judge
Comparison Table
| Area | Governing Rules | Document Name | Typical Length | Mandatory? |
|---|---|---|---|---|
| Civil | CPR + PD 52A (Section V) | Skeleton Argument | Concise (often up to 25 pages on appeal) | Usually yes, especially on appeals |
| Criminal | CrimPR + Practice Directions 2023 | Skeleton Argument | Subject to court directions | Common in complex/contested cases |
| Family (Financial) | FPR PD 27A | Position Statement (incl. skeleton) | 6–15 pages (stage dependent) | Yes for most hearings |
| Family (Children/Other) | FPR PD 27A + PD 30A | Position Statement / Skeleton | Up to 20 pages | If appropriate |
Conclusion
The skeleton argument (or position statement in family cases) is an essential bridge between written statements and oral advocacy in the UK courts. Whether in civil, criminal, or family proceedings, the golden rules remain the same: clarity, brevity, and precision.
A well-crafted skeleton or position statement does not merely summarise the case, it persuades the court before a single word is spoken in the hearing.
Check out the related articles on the Attorney General, Solicitor General, Lady Chief Justice, Master of the Rolls, Lord Chancellor, Justice Secretary, Rule of Law, Open Justice, Law, Is the Law Black and White ?, Government Legal Department, Crown Prosecution Service (CPS), Abuse of Process, Government Legal Department (GLD), What Does Lady Justice Symbolise ?, McKenzie Friend, Can a Judge Direct a Jury to Find a Defendant Not Guilty ?,Law Society, Law Commission, McKenzie Friend Right of Audience, Solicitors, Solicitors Regulation Authority, Barristers, Bar Council of England and Wales, Bar Standards Board, R v Sussex Justices, Police Impartiality and the highly questionable Sussex Family Justice Board.
The Ministry of Injustice is not the Ministry of Justice nor is it affiliated in any way with the justice system, legal profession, police or any other law enforcement agencies.
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[post_title] was last updated on the 9th June 2026
