One Pump Court Chambers
This seminar will cover
CPR 32 – Evidence
Unfortunately, rules, practice directions and guidance as to the content of witness statements appear to be habitually ignored by practitioners
Cummings v MoJ  EWHC 48 (QB), per Tugendhat J, paras 8 and 9.
The Purpose of Witness Statements
2.1 reducing the length of the trial (by largely doing away with the need for anything more than short examination-in-chief);
• enabling the parties to know in advance of the trial what the factual issues are;
• enabling opposing parties to prepare in advance for cross-examination;
• encouraging the early settlement of actions;
• providing useful and relevant information to the court to enable it to adjudicate upon the case in an efficient manner.
What Should Not Be in a Witness Statement
• Putting the other side’s case
• Commenting extensively on the expert report
• “My solicitor advised me …” and legal privilege.
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