There is no order but chronological order

Chronological order – that is to say, date order – is the only way to arrange the papers in a hearing bundle. Anything else will be confusing at best, enraging at worst.

Admittedly part of the reason why this is the best way to arrange the papers is that it is the most common way. That’s not an argument that always works: the most common way to sing is out of tune, after all, and the most common way to paint a sash window is so that the top half is jammed permanently shut. But when it comes to bundles (like deciding on which side of the road to drive), tedious conformity to usual practice is by far the best thing. The parties’ representatives will have to navigate the bundle at speed in the course of the hearing, and it is much easier to navigate at speed if you know your way around.

The one exception to strict chronological order is the formal tribunal documents – the ET1, ET3, together with any questionnaires and responses, requests for additional information and responses to such requests. It is conventional to put these in a separate section right at the front of the bundle. Some people also put any grievances that are required to found the claim in this section, too, and that’s not a bad idea.

But after that, resist any temptation to subdivide by theme (‘investigation,’ ‘disciplinary proceedings,’ ‘grievance about photocopier incident,’ ‘disciplinary appeal’ etc). Just arrange all the documents in the order in which they were written.