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PRACTICE DIRECTION HC97 – Written Submissions and Issue Papers




On the 18th September 2020, the President of the High Court issued a Practice Direction in relation to written submissions in respect of civil proceedings.
The Practice Direction does not apply to any proceedings before the Commercial Court.

The Practice Direction outlines that;
  1. Written Submissions must include;
  • The date, title and record number of the case. They should indicate on whose behalf they are presented and counsels’ names should appear at the bottom where appropriate.
  • The written submission must be on A4 paper, printed on one side, font size 12 and Times New Roman. 1.5 line spacing and margins of 3.25cm at each side and 2.5cm at top and bottom;
  • No more than 5,000 words and no footnotes unless otherwise advised by the court.
The layout of the Written Submissions should include an introduction, the principal issues in the case, the submissions pertinent to those issues, any conclusions and an indication of the orders to be sought.

In addition, the Written Submissions should include a chronology of relevant facts and of procedural history
The respondent/ notice party should indicate in its submissions if the chronology is agreed. Where it is not agreed, the respondent/ notice party should produce his or her full chronology identifying clearly the points of difference, preferably in bold.
  1. Books of Authorities
The Court has introduced its own Book of Authorities for applications including applications for discovery, costs, delay and/or abuse of process and any other matters as may be listed from time to time on the Court's website.

A list of the authorities contained in the Court’s own Book of Authorities will be available on the Court’s website as of 18th September, 2020 and will be kept updated.

Books of Authorities in the above-mentioned applications should only include authorities not identified in the Court’s own book.

Only authorities which will be referred to in oral argument are to be included and there are no more than 8 cases to be included.

Joint Book of Authorities are to be agreed no later than the date for delivery of the appellant’s Written Submissions.
  1. Issue Papers
The parties should agree an issue paper which states the issues to be determined clearly.

Where there is no agreement as to the issues, each party should submit an issue paper setting out concisely
what they consider the issues to be. Issue papers are to contain no more than 1,000 words.
  1. Filing of Written Submissions and Issue Papers
A soft copy is to be emailed in Word format to and a hard copy is to be delivered to the Central Office.
  1. Consequences of non-compliance
When the court is considering making any order for costs to which this practice direction applies, consideration will be given to compliance or as the case may be, non-compliance with the Practice Direction.

A full copy of the Practice Direction is available here.

Written by Mark Kelly
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