Statement of Issues

Below is a statement of issues. This is what you are asking the judge to decide upon at the hearing. It should include all things that you don’t agree on with the other party. Don’t include things that are already agreed upon. If you are represented by a solicitor, you will be at his mercy as to what he will ask for. He may not wish to upset the judge or may have made an agreement with the other side.

Keep it short, simple and clear. What you are asking for must be achievable. There are two types of issues. The first is rulings and the second is orders.

A ruling is a decision you are asking the judge to decide on. It is in the form of a declaration. For example asking the judge to declare that the father has residence. An order is when one or other parties are ordered to do or not do something.

Everything in your position statement must support these issues. In other words what you write in the position statement must persuade the judge to award what is in your position statement in your favour. For example your position is that the mother is mentally ill. The issue would be to appoint a psychologist to examine the mother’s mental health. Or your position might be that shared residence will prevent the mother abusing her power as the resident parent. The issue would be to award shared residence.



IN THE LIVERPOOL HIGH COURT                              CASE NO: LV01P0XXXX



M Punch                          Applicant
G Judy  Respondent


Statement of Issues for the hearing on the 06/10/04


    1. The court order of Justice Baron in the high court dated 6th July 2004 is to be implemented with a clearly defined schedule of contact between father and child with a penal notice attached.


    1. CAFCASS is to be discharged as L’s Guardian.


    1. The ban from the Wirral is to be discharged.