Step-by-step
- Use a clear headingInclude the court, case number, parties, hearing date and the party filing the document.
- State the hearing purposeBriefly identify what the court is being asked to deal with.
- Give only necessary backgroundA short chronology is usually clearer than a complete relationship history.
- Identify the key issuesUse headings or numbered paragraphs for the matters relevant to this hearing.
- State your position factuallyExplain what you agree with, what you dispute and why, using document references where appropriate.
- Keep the child centralDescribe impact and proposals in terms of welfare, stability and practical needs.
- Say what you ask the court to doList the order or directions requested in clear, workable terms.
- Check format and filingFollow page limits, deadlines, service requirements and any local or case-specific direction.
Accusatory wording compared with factual wording
| Less helpful | More factual and child-focused |
|---|---|
| “The other parent is selfish and always ruins contact.” | “On 4, 11 and 18 October the arranged handover did not take place. I ask the court to consider a written handover plan to give the child greater consistency.” |
| “Cafcass ignored everything.” | “Paragraph 18 records the school meeting as 6 May. The school email at page B12 confirms it was 16 May. I ask that this factual point be corrected.” |
What you will need
- Correct case heading
- Purpose of this hearing
- Concise relevant background
- Numbered key issues
- Evidence or bundle references
- Child-focused proposals
- Specific order or directions requested
- Deadline and service check
Common mistakes to avoid
- Turning the document into a witness statement
- Personal insults or inflammatory labels
- Including irrelevant message screenshots
- Making claims without identifying their source
- Ignoring the page limit or filing deadline
Practical paid support
How I can help
Position Statement Preparation
£149 standard / from £249 complex
The standard package covers an initial discussion, review of up to 20 pages, one draft, one round of amendments, and final editable and PDF copies. Extensive, urgent or unusually complex work is quoted separately.
Included
- Discussion up to 30 minutes
- Review of up to 20 pages
- One draft based on your facts and instructions
- One round of amendments
Not included
- Extensive document review
- Additional statements
- Urgent deadlines
- Filing and service
We aim to respond to all enquiries within 24 hours.
Frequently asked questions
How long should it be?
Use the limit in the court’s directions. Current procedural guidance may set default limits for certain hearings, but case-specific directions take priority.
Is a position statement evidence?
It usually sets out a party’s position for a hearing and is not a substitute for evidence required in a witness statement.
Official sources
- Family Procedure Rules: Practice Direction 27A ↗
- Family Procedure Rules: Practice Direction 12B ↗
- Judiciary: Preparing court bundles — guide for litigants in person ↗
Guidance checked: 1 November 2026. Always check the latest court order and official source before acting.
Important: This page gives general procedural information for England and Wales. The Everyday McKenzie Friend provides independent, non-regulated practical support and is not a solicitor or barrister. I do not provide regulated legal advice, conduct litigation or have an automatic right to address the court. Court decisions and permission for McKenzie Friend assistance remain matters for the court.