How to Draft Particulars of Claim: How much information to include

[marlo]

I am currently drafting a Particulars of Claim Form against six Defendants. The Civil Procedure Rules state:
"1) Particulars of claim must include – (a) a concise statement of the facts on which the claimant relies"

I have also read from another source that a Particulars of Claim must not include evidence as that is included in the witness statement.

How to you differentiate between "facts upon which you rely" and "evidence". Surely they are the same thing?

I am trying to be "concise" but my Particulars of Claim currently runs to 35 pages. Is this excessive.

[R0b]

Re: How to Draft Particulars of Claim: How much information to include

You would usually see a 35 page page particulars of claim or thereabouts if the monies claimed for is 6 or 7 figures and/or are highly complex situations. In any other case, that's probably far too excessive (assuming its not double spaced).

You don't need to state everything that has gone on but you need to pick out key and relevant dates. In terms of evidence, if the agreement was a written agreement then you need to include that in your particulars of claim. You can sometimes add one or two extra documents if they are central to the claim and perhaps relate to the contract but everything is usually contained in the witness statement.

What is the value of the claim, and what's your background to it i.e. what does the claim relate to?