How to Write a Skeleton Argument: Structure, Format, and Filing

To write a skeleton argument, set out in numbered paragraphs the order you want the court to make, the facts and law that support it, and the argument that connects them — all within the length and format rules of the court hearing your case. Practice Direction 52A describes the document’s purpose as assisting the court “by setting out as concisely as practicable the arguments upon which a party intends to rely.”¹ That phrase does a lot of work. Everything that follows in this guide flows from it.

Start With the Order You Want

Before writing anything, decide what you are actually asking the court to do. An injunction? Dismissal of a claim? Permission to appeal? Damages in a particular sum? The whole document is built to persuade the judge to make that specific order, so you need to know what it is in words the court could adopt directly.

A skeleton is not a written submission in miniature and not a rehearsal of your witness statements. Its job is to give the judge a roadmap: here is what I want, here is why the law allows it, here are the facts that fit. Judges have limited pre-reading time, and a skeleton that buries its points in long extracts from authorities defeats its own purpose. Practice Direction 52A prohibits extensive quotations from documents or authorities for that reason.¹

Every skeleton argument must also define and confine the areas of dispute between the parties, cross-reference the hearing bundle, and stand on its own. You cannot incorporate material from a previous skeleton by reference; if a point is still live, restate it.¹

The Structure That Works

There is no single compulsory template, but most well-drafted skeleton arguments follow a four or five-part structure.²

Introduction. One short section stating the order or decision you want and the core reason the court should grant it. If the judge reads nothing else, they should understand your position from this.
Factual background. A concise summary of the facts that bear on the legal issues, cross-referenced to the hearing bundle. Leave out facts that do not matter to the legal question. A chronology is necessary in most appeals and helpful in many other hearings.¹
The law. The statutes, regulations, and authorities you rely on, with the most important ones first.²
Legal argument. How the law applies to your facts. This is where you do the real work of persuasion. Explain the reasoning that gets the court from the authorities to the order you are seeking.
Conclusion. A clear restatement of what you want the court to order.²

The conclusion matters more than people realise. If you do not spell out the specific relief, the judge has to guess what you are asking for. Give them wording they could lift directly into an order.

Each paragraph should be numbered and address a single point or sub-issue.¹ This is not stylistic. Judges and opposing counsel refer to paragraph numbers during the hearing, and unnumbered blocks of text make that impossible.

Citing Cases and Legislation

When you cite an authority, state the legal proposition it establishes and identify the specific paragraphs of the judgment that support it.¹ If you cite more than one case for the same point, briefly explain why both are needed. Judges react badly to padded authorities lists. Eight cases strung together for a single unremarkable principle signals that the author has not identified which one actually matters.

For well-established principles, a reference to a recognised textbook with the relevant extract is often enough.³ You do not need to produce the full judgment in Donoghue v Stevenson to argue that a duty of care exists. Copies of all cited authorities should be lodged with the court no later than when the skeleton itself is filed.

The same discipline applies to facts. Every factual assertion should carry a reference to the page or tab in the hearing bundle where the supporting document sits.¹ “[Bundle/Tab 4/p.37]” is useful. “[see the Bundle]” is not. A judge who has to hunt through hundreds of pages to verify a claim in paragraph 12 is a judge whose patience is eroding.

Format and Length

Formatting rules vary by court but share a common baseline: numbered paragraphs, at least 12-point font, 1.5 line spacing, A4 if printed.⁴ No practice direction specifies a typeface, so you have some freedom on that.

Length limits are where the differences bite:

Court of Appeal: normally no more than 25 pages.⁴
Competition Appeal Tribunal: 20 pages for an applicant or claimant, extending to 25 only when a respondent faces multiple separately represented opposing parties.⁵
Chancery Division: 25 pages for heavy applications, up to 50 pages for trial skeletons.

If you need to exceed any stated limit, you must write to the court in advance and explain why. Always check the specific guide for the court you are filing in; local rules can add requirements that override the general standards.

When to File and How to Serve

Deadlines turn on which court and which hearing. In the Court of Appeal, an appellant files a skeleton with the appellant’s notice, and further deadlines run from the Listing Window Notification Letter.⁴ In the Business and Property Courts, the skeleton must be lodged no later than two clear business days before the hearing.³ Chancery Division heavy applications must be filed by 12 noon, two clear days before the hearing or the start of a floating hearing window. At county court and district level, deadlines are often set by individual case management orders; where no specific order has been made, a common default is between two and five days before the hearing.⁶

Serve the opposing party at the same time you file. Simultaneous service is the default across all courts, and the Court of Appeal guide is explicit about it.⁴ The other side needs the same preparation time as the judge; serving late invites an adjournment application you do not want.

Courts on the CE-File system expect electronic filing, with PDFs up to 50MB.³ Some courts, particularly at county level, accept email. Submitting through the wrong channel can mean your document is not treated as filed on time.

Missing a deadline carries a direct financial penalty. Under Practice Direction 52A, the costs of preparing a skeleton that is late or non-compliant will not be allowed on assessment unless the court directs otherwise.¹ Your client absorbs the cost even if you win. Judges can also refuse to consider a late skeleton, forcing you to argue orally without the framework you prepared, or adjourn the hearing at the defaulting party’s expense. Where a lawyer’s conduct has been unreasonable or negligent, a wasted costs order can require the legal representative personally to compensate the other side.

What to Avoid

The most common error is writing something that reads like a full written submission in disguise. If your draft runs close to the page limit and contains long passages of quoted case law, you have lost sight of the point. Judges will read the authorities. Your job is to tell them which parts matter and why.

Other patterns to watch for:

Dumping the entire factual narrative rather than distilling the facts that bear on the legal question.
Failing to cross-reference the bundle, so the judge cannot quickly check what you say.
Citing authorities without pinpointing the paragraphs that support your proposition.
Incorporating earlier skeletons by reference, which Practice Direction 52A prohibits outright.¹
Omitting a clear statement of the order you want the court to make.

Courts regularly comment on overlong and unfocused skeletons. Advocacy that respects the judge’s time gets a better reception before anyone has stood up to speak.

If You Are Representing Yourself

A skeleton argument can feel like one of the more technical documents in civil litigation. Courts do not expect the same polish from a self-represented party that they expect from a barrister. They do expect a clear, honest explanation of your position.

Focus on two things. First, explain briefly what the case is about and what order you want the court to make. Second, set out the main reasons the court should make that order, with reference to any relevant law or evidence. You do not need to write in legal language or cite dozens of cases. A clearly structured document with numbered paragraphs that identifies the issues and points to the key documents in the bundle will serve you far better than an attempt to mimic a lawyer’s style. The four-part structure from the SRA’s template — introduction, facts, law, conclusion — works well for litigants in person.²

Supporting Documents

A skeleton rarely stands alone. Practice Direction 52A notes that parties should consider what other information the court will need, which may include a chronology of relevant events, a list of key individuals, or a glossary of technical terms.¹ A chronology is necessary in most appeals and helpful whenever the sequence of events is disputed or complex.

You will also need a list of authorities — the cases, statutes, and any textbook extracts you intend to rely on. Copies must be lodged with the court no later than when the skeleton itself is filed.³ The skeleton should identify which authorities support which propositions, so the judge can pre-read the relevant passages efficiently rather than working through an undifferentiated stack of judgments.

1
Justice UK. Practice Direction 52A – Appeals
2
Solicitors Regulation Authority. Drafting a Persuasive Skeleton Argument
3
Courts and Tribunals Judiciary. Guide to the Preparation and Service of Bundles, Skeleton Arguments and Authorities in the Business and Property Courts
4
Courts and Tribunals Judiciary. Court of Appeal (Civil Division) Guide 2025
5
Competition Appeal Tribunal. Practice Direction 1/2021 – Skeleton Arguments and Bundles for Hearing
6
Courts and Tribunals Judiciary. Annex B County Court at Central London – Skeleton Argument Protocol