Witness statement template

In small claims, witness statements stand as evidence-in-chief. Under CPR 32.5, the witness's written statement is treated as their oral evidence at the hearing — they are not asked to repeat it. The judge reads the statement, and the witness is then available for questions from the other side and the judge.

Witness statement template

Why witness statements matter

This makes the statement central. A clear, well-organised, factual statement with proper exhibits gives the judge most of what they need to decide the case. A rambling, argumentative, or factually thin statement — even from a sympathetic witness — undermines the case before any cross-examination begins.

CPR Part 32 and its Practice Direction set out the format. The template below follows that format. The substance — what to include — depends on your case, but the structural rules are universal.

A4 paper, 12-point font, double spacing, numbered paragraphs, headings in bold. Page-number every page.

What to include and what to leave out

Include facts you witnessed personally, conversations you had or overheard, documents you sent or received, and the chronology of events as you experienced them. Reference each document by exhibit number and page so the judge can find it instantly.

Leave out: legal argument (save that for your closing submissions), opinions about the law, characterisations of the other party's character or motives, and anything you do not actually know. Hearsay is admissible in civil proceedings but should be flagged as such ("I was told by X that…"). Keep adjectives spare.

A useful test: would the statement read sensibly to a complete stranger who knew nothing about the dispute? If yes, it is doing its job.

The statement of truth

Every witness statement must conclude with a statement of truth in the wording set out in CPR 22.1. Signing without honest belief in the contents is contempt of court — punishable by fine or imprisonment. The court takes false statements seriously; perjury prosecutions arising from civil witness statements are not common but do occur.

If your witness cannot honestly stand by every paragraph, take the doubtful paragraphs out. A shorter, accurate statement is always better than a longer, exposed one.

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