How to write a position statement for family court: template, example and the 2026 rules

What a position statement is

A position statement is a short document setting out your position for one particular hearing. The judge usually reads it before you go into court, so they already know what you want and why.

Practice Direction 27A, the rule on court bundles, describes it as a written submission on the issues to be decided at that hearing. The judiciary's guide for people without a lawyer calls it "a short document that explains a party's position for that hearing".

It isn't evidence, so the facts in it aren't tested the way a witness statement's are. Each parent writes their own, and your ex doesn't have to agree with yours.

It helps on the day as well: hearings move quickly, and a copy in front of you lets you point the judge to paragraph 4 instead of relying on memory. For the wider legal picture, read our guide to child arrangements law in the UK.

Position statement, witness statement or chronology?

The front of a court bundle holds several short documents, each with a different job to do. Mixing them up is how a position statement ends up far too long.

Your court order says which documents the judge wants, and until it asks for a witness statement, keep your full account of events for later.

The rules since 2 March 2026

A new Practice Direction 27A came into force on 2 March 2026, covering every family court hearing whether or not you have a lawyer. For children cases, paragraph 7.18 says a position statement should:

1. Be short. No more than 3 pages, unless the court accepts the case is complex and sets a different limit.
2. Stick to this hearing. It should define and confine the issues the judge has to decide now.
3. Use numbered paragraphs. The judge and the other side can then refer to them quickly.
4. Point to the bundle. Refer to documents by their bundle page rather than copying them out.
5. Stand on its own. Don't rely on wording from an earlier position statement.
6. Leave out new evidence. Exhibits and long quotations from documents don't belong in it either.
7. Say what you want. Set out the orders or directions you're asking the court to make.
8. Cover settlement where it applies. Where relevant, give your view on mediation and other ways to resolve things out of court.

Other parts of PD27A add a few more points. Paragraph 7.10 says it should summarise the order you want both at this hearing and at the final hearing. It should also show the date you prepared it and the hearing date, just under the heading (paragraph 7.13).

Paragraph 7.20 requires a new position statement for each hearing, so adding an "update" section to last time's statement isn't acceptable. For paper bundles, paragraph 12.2 asks for 12-point type or larger, 1.5 or double spacing and margins, in Arial or Times New Roman where possible.

Your court order always comes first: if the judge has set a different deadline or page limit, follow the order.

Do you have to write one?

PD27A lists a position statement from each party among the documents at the front of the bundle. The judiciary's guide adds that not every document is needed at every hearing, so check your latest order.

If your order asks for one, you must file it, and if it doesn't, a short one is still worth the effort. Coram Children's Legal Centre notes the judge will usually read it before the hearing, which gives you the first word in your own terms.

What to put in it, paragraph by paragraph

Start with one question, what is the judge being asked to decide at this hearing, and make every paragraph help answer it.

1. Heading. The court, case number, applicant and respondent, and a title such as "Position statement of the mother for the FHDRA on 15 July 2026". Add the date you prepared it.
2. Who you are. One or two lines: your role, the children's first names and ages, and where they live now.
3. What this hearing is for. For example a first hearing, a dispute resolution appointment or a final hearing.
4. What you're asking for now. The order or directions you want at this hearing, such as interim weekend time or a section 7 report.
5. What you want at the end. One line on the final order you're aiming for.
6. Why. Your main reasons, one per paragraph, each resting on a dated fact.
7. Safety. Anything the judge must know at once, and any help you need to take part safely.
8. Agreement and mediation. What is agreed, what is still disputed, and where mediation stands.
9. Sign-off. Your name and the date.

Courts decide children cases using the welfare checklist in section 1(3) of the Children Act 1989. Framing your reasons in its terms helps: the child's needs, their wishes and feelings, the effect of change and any risk of harm. Our guide to what judges look for in child arrangements cases goes through each factor.

IN THE FAMILY COURT AT [COURT]
CASE NUMBER: [number]
[APPLICANT NAME] (Applicant) and [RESPONDENT NAME] (Respondent)

POSITION STATEMENT OF THE [MOTHER/FATHER] FOR THE [HEARING] ON [HEARING DATE]
DATE PREPARED: [date]

1. I am the [applicant/respondent] and the [mother/father] of [child's first name], aged [age]. [Child] lives with [name] at present.
2. This is the [hearing]. The court is being asked to decide [issue].
3. At this hearing I ask the court to [order or directions].
4. At the final hearing I will ask for [final order].
5. [Reason 1: a dated fact] (bundle page [ ]).
6. [Reason 2: a dated fact] (bundle page [ ]).
7. Safety: [any risk, and any special measures I need, or "None"].
8. Agreement and mediation: [what is agreed, what is not, and my position on mediation].
9. I ask the court to [repeat the orders sought].

[Your name]
[Date]

A worked example

Here is a short, fictional example for a first hearing, which runs to about 250 words and sits well inside the page limit.

In the Family Court at [Town], case number AB12C34567: Hart v Lowe.

Position statement of the applicant mother for the FHDRA on 15 July 2026, prepared on 10 July 2026.

1. I am Sophie Hart, the applicant and the mother of Mia, aged 7. Mia has lived with me since March 2026.
2. This is the first hearing. I ask the court to make an interim order and give directions.
3. I ask for an interim order that Mia spends alternate weekends with her father, from Saturday at 10am to Sunday at 5pm. Handovers would take place at a public place.
4. At the final hearing I will ask that Mia lives with me and spends regular time with her father, including half the school holidays.
5. Mia needs a predictable routine. Between April and June 2026, 6 of 11 planned handovers started more than an hour late or did not happen. My records and the related messages are available if the court wants them.
6. On 14 June 2026 Mia's father did not collect her from school as agreed. The school's record of that day is available.
7. I support Mia's relationship with her father. I have offered a video call every Wednesday at 6pm.
8. I attended a MIAM on 2 May 2026. I remain open to mediation about the school holidays.
9. I ask the court to make the interim order at paragraph 3 and to consider whether a section 7 report is needed.

Sophie Hart, 10 July 2026

Notice what it leaves out: the life story, adjectives about the other parent and screenshots. Paragraph 5 does the work with a date range and a count.

Write it for the hearing in front of you

The same template works for every hearing, but what the judge needs from you shifts as the case moves on.

Our guides to the FHDRA, the section 7 report and the fact-finding hearing cover those stages in detail. By the first hearing, Practice Direction 12B says the court should have the C100, the C7 response, any C1A form and the Cafcass safeguarding letter. There's no need to repeat what's in them, so refer to them by name instead.

The first hearing isn't confidential either. PD12B says what is said there may be referred to later, so write every line as if it could be quoted back.

Facts that persuade, wording that backfires

Judges read position statements quickly. A specific, dated fact is easy for them to act on, while a general complaint is just as easy to set aside.

Since March 2026, paragraph 5.2 of PD27A has kept texts, WhatsApp messages, photos, voice notes and notes of contact visits out of the bundle. The exceptions are when the court directs otherwise or a specific item is needed for the hearing. Name the message by date instead, and say it's available. Our guide to writing factual incident reports shows the same style for your own records.

Raising domestic abuse or safety concerns

A short statement doesn't mean staying quiet about abuse. Put safety near the top, where the judge can't miss it.

• Name it plainly. Say what happened and who was affected, in one or two sentences.
• Link it to your request. Explain why it matters for this hearing, such as why contact should be supervised or a fact-finding hearing is needed.
• Give two or three dated incidents. The most serious ones are clearer than a full history.
• Point to the records. Police reference numbers, medical records or the Cafcass safeguarding letter, by name and bundle page.
• Ask for what you need to take part. Under section 63 of the Domestic Abuse Act 2021, a victim of domestic abuse is assumed to be vulnerable for this purpose. That opens the door to special measures, such as a screen in court or a video link. The court still decides, so ask in your statement and contact the court early.

If you've applied to keep your address private with form C8, leave it off your position statement too. The form itself warns that court staff can't check your documents for accidental disclosure.

Sending it: who, when and how

PD27A sets a timetable for every hearing in paragraph 13.2, unless your order says otherwise. Position statements are among the front documents, which must reach the court and every party by 11am on the working day before the hearing.

The applicant usually prepares the bundle, although a represented respondent takes over when the applicant has no lawyer (paragraphs 4.5 and 4.6). Send your statement to the court and the other parties by the deadline, and to whoever is preparing the bundle well before that.

Sending it late carries real risk: the judiciary's guide warns that the judge may not read it, may delay the hearing and may order costs. If you can't meet a deadline, contact the court as soon as possible and explain why.

On the day, take a printed copy for yourself and keep it in front of you.

Why your record matters more than the wording

A position statement is three pages at most, and the judge may read it in a few minutes. What makes it land is the facts underneath: dates, counts and records the other side can't easily dispute. Those are hard to rebuild from memory in the week before a hearing, when you're already under pressure.

You'll also write more than one. PD27A asks for a new statement for every hearing, and a typical case runs from a first hearing to a dispute resolution appointment and then a final hearing. Each statement needs fresh facts for the period since the last one.

1. Filter to the period that matters. Usually the months since the application or the last order.
2. Count, then pick. Totals like "6 of 11 handovers" come straight from a log. Then choose the two or three entries that matter most.
3. Quote dates, not memories. Each fact in your reasons should match an entry you can show.
4. Keep the detail ready. If the court orders a chronology, each entry becomes one line, up to 10 pages. If the judge asks to see a message, you can find it quickly.

Casewell keeps that record on your phone. Log each handover, missed call, message and incident as it happens, with the screenshots and photos behind it. Every entry shows when you recorded it, and later edits stay visible, so it's clear which notes you made on the day. Add your schedule, and the report counts scheduled handovers and how many you recorded as late or missed, ready for a paragraph like number 5 in the example.

When a hearing is listed, export the period as a clear PDF chronology for your solicitor, McKenzie friend or Cafcass adviser. Your record is yours alone and depends on no one else's cooperation. Start it now, and your next position statement begins with the facts already in order.