Civil Litigation

Lady Justice Arden (at para 30) gave guidance on the use of plans, maps, diagrams and photographs in court. Those who prepare bundles or skeleton arguments should remember that a plan, map, diagram or photograph which is clear to people who are fully familiar with the case may well not be wholly clear to a judge coming to the case for the first time.

It is essential that, where the court is going to have to grapple with plans, maps, diagrams or photographs, there is at least one plan, photograph or map which leaves the court in no real doubt about the location of all the relevant features. The skeleton arguments should identify that photograph, map, plan or diagram at an early point. It is also essential that, in the case of plans, photocopies have the colouring referred to in the original documents and should have a statement of the scale.