‘Skeleton Arguments for interim applications should not exceed 15 pages’: –

The updated version of the Chancery Guide specifies that Skeleton arguments for interim hearings should not normally exceed 15 pages. Paragraph 6.57 states:

‘Skeleton arguments should be no longer than is necessary. They should normally not exceed 15 pages. Even in the heaviest cases they should not exceed 25 pages (including any appendices and schedules). Should a party wish to file a longer skeleton argument, the senior legal representative whose name appears at the end of the skeleton argument must file a letter along with the skeleton argument explaining why this has been necessary. A desire to be of greater assistance to the court is rarely a good reason: overly long skeletons do not assist. If the Master or HCJ is not satisfied by the explanation the party may be required to re-draft the skeleton argument and/or costs sanctions may be imposed. For further guidance on skeleton arguments generally see Appendix Y.’

Note also that para 14.43 states:

‘Skeleton arguments for ordinary applications should be no longer than is necessary. They should not exceed 15 pages (including any appendices and schedules) and should be skeletons, not full written arguments. Should it exceptionally be considered necessary to file a longer skeleton argument, the legal representatives whose names appear at the end of the skeleton argument must file a letter along with the skeleton argument explaining why this has been necessary. A desire to be of greater assistance to the court is rarely a good reason: overly long skeletons do not assist. If the Master or HCJ is not satisfied by the explanation, the party may be required to re-draft the skeleton argument and/or costs sanctions may be imposed. For further guidance on skeleton arguments generally, see Appendix Y.’

Paragraph 12.51 further states that Trial Skeleton Arguments, should not normally exceed 25 pages. ‘Even in the heaviest cases they should not exceed 50 pages in length, including appendices and schedules (minimum font size of 12 point and 1.5 line spacing).’

In paragraph 5.26.1 (Legal argument and reasoning), of my forthcoming book, the 2nd Edition of the Contentious Probate Handbook, which is scheduled for publication by the Law Society in mid to late February 2025, I write:

‘As the late and great Mr Justice Hunt remarked in a lecture to the South Eastern Circuit Bar Mess entitled, ‘The Art of Advocacy’:

Do not embark on your case like Christopher Columbus, who on his voyage of discovery, did not know:

(i)      where he was going;
(ii)     when he arrived, where he was; and
(i)      after he had been there, where he had been!

Know where you are going, and when you have got there sit down.

Set out what you want in paragraph 1 of your skeleton argument, “the Claimant’s case is …” Set out your stall, what you are asking for and want the judge to do.

Say to yourself – “what am I doing here? What is my case?”

Your opening is the route-map for your case containing the clearest sign-posts to point the judge in the right direction.

Thus, the first Golden rule of advocacy is that before starting out know where you are going, how you are going to get there, and what you need to say and prove, so that the Judge will follow you to your planned destination!’

Your Skeleton Argument is the route-map for winning your application/case at trial. So do not turn it into a travel almanac! The judge is not going on holiday to Italy. What he needs is a succinct summary of what you are asking him to order, and of why he should grant the directions/remedies you seek. Thus in written advocacy, less is more. In other words, the acme of persuasion is brevity.