Does a personal injury claim need a paginated bundle? What the rules actually say

For PI fee-earners and paralegals · ~5 min read · quotes from official CPR sources

What the PI Protocol actually requires

The Pre-Action Protocol for Personal Injury Claims sets out disclosure obligations and, where a medical expert is instructed, requires the claimant's solicitor to organise access to the relevant records (paragraph 7.5). For fixed-cost whiplash claims, the expert may not even need to see the records at all. What it does not contain is any specific rule requiring records to be indexed, paginated or delivered in a particular bundle format before proceedings start — a genuine contrast with the clinical negligence Protocol, which requires an indexed and paginated bundle "at the earliest opportunity."

Where the requirement actually comes from

Once a personal injury claim is heading to trial, a different rule takes over. CPR Practice Direction 32, paragraph 27.8 states:

"The trial bundle should be paginated (continuously) throughout, and indexed with a description of each document and the page number."

CPR Practice Direction 32 — Evidence, para 27.8

So the honest answer is: not required at the outset, but required by the time a matter is heading to a hearing — and by then, re-organising a large, live record set from scratch is a far bigger job than keeping it paginated as records arrive.

The rule most firms miss: pagination must be computer-generated

Official guidance on electronic bundles goes further than "paginated" — it specifies how:

"E-bundles must be provided in pdf format. All pages in an e-bundle must be numbered by computer-generated numbering, not by hand."

Courts and Tribunals Judiciary — General guidance on electronic court bundles

Hand-numbered pages, or a page count that drifts because pages were added after numbering, don't meet this. It has to be a genuinely continuous, machine-generated sequence across the whole bundle.

What this means in practice for a PI file

• Pre-action, pagination is good practice, not a rule — but a well-organised record set makes assessing the claim, instructing an expert and negotiating all faster regardless.
• Once trial becomes a realistic prospect, PD 32 applies — continuous pagination and an index become mandatory, not optional.
• The numbering must be computer-generated across the whole bundle, matching the actual PDF page — see our fuller guide on what electronic pagination requires.
• Records accrue over the life of a claim — a bundle assembled once, early on, will need re-pagination as more records arrive; building it in a way that's cheap to redo saves real time later.

Quotations are from the Pre-Action Protocol for Personal Injury Claims and CPR Practice Direction 32 as published on justice.gov.uk, and Judiciary guidance on electronic bundles; check the current text directly for any matter where precise compliance matters. General information for legal professionals, not legal advice.