How to write a witness statement for small claims court (CPR 32)

A witness statement is your primary factual evidence in the small claims track. In England and Wales, County Court directions (Form N157) typically require both parties to exchange signed witness statements and document bundles at least 14 days before the hearing date.

What a witness statement must contain

Under Civil Procedure Rules (CPR) Part 32 and Practice Direction 32, every witness statement must comply with strict structural rules:

• Top matter (heading): State the court name, claim number, claimant and defendant names, the witness initials and surname, statement number (e.g. 1st Statement of J. Smith), exhibit identifiers, and the date of the statement.
• Introductory paragraph: State your full legal name, residential address, occupation, and your role in the proceedings (e.g. "I am the Claimant in this matter and I make this statement in support of my claim").
• Factual narrative in chronological order: State the facts in the exact order they occurred. Each event must have an approximate or exact date.
• Numbered paragraphs: Every paragraph must be sequentially numbered (1, 2, 3...) and deal with only one distinct factual point or event.
• First-person perspective: Write in the first person using "I" (e.g. "I telephoned the Defendant on 12 May 2026", not "The Claimant called").
• Facts, not legal argument: Only state what you personally saw, heard, did, or experienced. Do not cite statutes, legal principles, or courtroom rhetoric—legal submissions belong in your opening and closing remarks, not in witness evidence.
• Mandatory Statement of Truth: You must sign and date the statutory statement of truth including the mandatory CPR 32.14 contempt of court warning.

How to reference exhibits

Documents supporting your statement (invoices, contracts, emails, photographs, bank statements) must be formally exhibited rather than pasted into the text:

• Give your exhibits a standard identifier combining your initials and a number (e.g. `[Exhibit JS/01]`, `[Exhibit JS/02]`).
• Introduce each document directly in your narrative: "On 14 June 2026, the Defendant sent an email agreeing to the refund. A true copy of this email is attached at [Exhibit JS/01]."
• Attach an Exhibit Cover Sheet in front of each document or bundle of documents, stating: "This is the exhibit marked [JS/01] referred to in the witness statement of John Smith dated [Date]."
• Number every page of your exhibit bundle consecutively so you can direct the District Judge to specific page numbers during the hearing.

Standard witness statement layout template

```

IN THE COUNTY COURT AT [COURT NAME]

CLAIM NO: [CLAIM NUMBER]

BETWEEN:

[CLAIMANT FULL NAME] (Claimant)

• and -

[DEFENDANT FULL NAME] (Defendant)

WITNESS STATEMENT OF [YOUR FULL NAME]

Witness: [Initials / Surname]

Statement No: 1

Exhibits: [Initials/01] - [Initials/05]

Date: [Date of statement]

I, [YOUR FULL NAME], of [YOUR RESIDENTIAL ADDRESS], [OCCUPATION], STATE AS FOLLOWS:

1. I am the Claimant in this claim. The facts stated in this witness statement are within my own personal knowledge, save where otherwise appears. Where facts are not within my direct knowledge, I state the source of my information and belief.

2. On [Date], I entered into an agreement with the Defendant for [describe agreement]. A true copy of the written agreement is attached at [Exhibit AB/01].

3. On [Date], [describe next chronological fact, e.g. payment made or delivery of goods]. Attached at [Exhibit AB/02] is a copy of the bank transfer confirmation.

4. [Continue with sequentially numbered chronological paragraphs...]

STATEMENT OF TRUTH

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed: ___________________________

Full Name: [Your Full Name]

Dated: [Date]

```

Common fatal mistakes to avoid

• Missing the 14-day exchange deadline: Under CPR 32.10, if you fail to serve your witness statement by the deadline ordered, you cannot give oral evidence at the hearing without express permission from the court.
• Serving only the court: You must deliver one copy to the court office and send an identical copy to every other party in the claim. Emailing the court does not serve the other side.
• Including unverified hearsay: If you mention something told to you by a third party, state clearly: "I was informed by [Name] on [Date] that [fact] and I verily believe it to be true."
• Omitting the contempt warning: Statements of truth that omit the mandatory wording regarding contempt of court proceedings can be rejected by the court under CPR Practice Direction 22.

Free national support

• Support Through Court: 0300 081 0000 - free, independent procedural support for litigants in person
• Citizens Advice consumer service: 0808 223 1133 - consumer dispute guidance
• HMCTS Courts and Tribunals Service Centre: 0300 123 7050 - general case queries

Need your court bundle prepared? The Casewright Small Claims Witness Statement & Bundle Builder formats your witness statement into CPR 32 compliant numbered paragraphs, creates exhibit cover sheets, and paginates your complete hearing bundle - flat £79. Independent information directory; link is a sponsored referral.

This guide provides general procedural information for England and Wales and does not constitute formal legal advice. Sourced from CPR Part 32 and Practice Direction 32 (justice.gov.uk).

Reviewed by Sean McNamara, 2026-09-07.