Employment Tribunals and CPR Rules on Witness Statements

Rules of the UK Courts are governed by the Civil Procedure Rules (CPR), the rules are then further supplemented by Practice Directions (PD).

According to PD 32: 17-20 a witness statement must:

1. Contain the name and number of the proceedings/Court/Division in the heading.

The top right hand corner on the first page must contain the following:

  • The name of party making the statement.
  • The initials and surname of the witness.
  • The number of the statement in relation to the witness.
  • The date the statement was made.

2. If feasible be in the witnesses own words.

3. Expressed in the first person i.e. I John Smith, I commenced employment with the Respondent …etc

4. State the full name of the witness, the witnesses’ place of residence (if the statement is made in a professional capacity, the address at which the employee works, his position and the name of his firm/employer).

5. State the occupation of the witness.

6. Clarify whether the witness is a party to the proceedings (or possibly an employee of such a party).

7. Contain Indications of which statements are from the witnesses own knowledge and which are from his information and belief (and the source of such information and belief).

8. Be verified by a statement of truth: i.e. “I believe that the facts stated in this witness statement are true”.

9. Identify and verify any exhibit.

10. In employment matters, refer to a document and identify it according to its location (i.e. page number) in the hearing bundle of documents.

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