Bates or consecutive: which page numbering your court expects
Page numbering sounds like the most trivial part of a bundle. It is also one of the most common reasons a bundle is non-compliant, because the rules differ by court and the wrong scheme is obvious at a glance. Here is what each court expects, and the mistakes that turn a well-assembled bundle into a rejected one.
The two schemes, in plain terms
There are two numbering systems in play. Consecutive Arabic numbering is what it sounds like: 1, 2, 3 through the whole bundle from front to back. Bates numbering works section by section. Practice Direction 27A defines it precisely: a system “where each section of a bundle is denoted by a letter, with each page in that section also being numbered, so that the first section begins at page A1, then page A2 and so on, and the second section begins at page B1, then page B2 and so on.” So Section A runs A1, A2, A3, Section B restarts at B1, and a reference to “C14” tells everyone exactly where to turn.
Family proceedings: it depends on the type of case
This is where people most often trip up, because the amended PD 27A splits family work in two.
Financial remedy proceedings use consecutive Arabic numbering. The documents must be paginated individually and consecutively using Arabic numbering throughout the bundle. The preliminary documents, which are usually filed later, are numbered consecutively too but kept as a separate sequence from the main bundle.
All other family proceedings, including children cases, use Bates numbering: Section A, then B, then C, each with its own page sequence. Applying consecutive numbering to a care case, or Bates numbering to a financial remedy bundle, is the wrong scheme for the proceedings and the court will see it immediately.
Court of Protection: either, but be consistent
The Court of Protection is more relaxed. PD 4B requires the preparing party to paginate the bundle, and allows it to be paginated “either in separate sections or sequentially.” So both schemes are open to you in the Court of Protection. What matters is that you choose one, apply it consistently, and that your index references match. If your case is also subject to case-specific directions from the judge, those come first.
Civil and tribunals: check the court guide and the directions
Outside the family jurisdictions, there is no single rule I can point you to, and I would be wary of anyone who claims otherwise. Civil bundles are generally paginated continuously from front to back, but the detail is governed by the applicable court guide, such as the King’s Bench Guide or the Business and Property Courts Guide, and by any directions the court has given in your case. Tribunals vary widely and usually set their own requirements in directions. The safe rule is simple: before you number anything, read the guide for the court you are in and any order that has been made.
The mistakes that catch people out
Even with the right scheme, a few errors recur:
The index gets numbered. The index sits at the front and is not part of the paginated sequence. Numbering it throws every reference out by a page.
The PDF viewer’s page count is treated as the pagination. The number your PDF reader shows in its toolbar is not the bundle’s page number. The pagination has to be applied to the pages themselves, so that “B12” is stamped on the page and means the same thing on every screen and in print.
The index no longer matches the pages. The moment a document is added, removed or reordered, the pagination and the index have to be regenerated together. An index pointing to the wrong pages is worse than no index at all.
The scheme is mixed. A bundle that starts in Bates and drifts into consecutive numbering halfway through, or numbers some sections and not others, is the hallmark of a bundle assembled by hand under time pressure.
Let the tool handle it
Every one of those mistakes disappears if the numbering is applied by software that knows the rules. That is what Court Bundle Builder does: choose your proceedings type, and it applies consecutive Arabic numbering or section-prefixed Bates numbering accordingly, leaves the index unpaginated, stamps the page numbers onto the pages themselves, and regenerates the index to match every time you change the contents. It is free, it runs in your browser, and your documents never leave your device.
Numbering is not the part of a bundle that wins a case. But getting it wrong is a needless way to start a hearing on the back foot, and it is entirely avoidable.
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