Form N163 Skeleton Argument UK: How to File & Page Limits

At a glance

• Content rules for every skeleton argument: set by Practice Direction 52A, Section V — concise, numbered paragraphs, cross-referenced to the bundle, self-contained, no extensive quotations.
• County Court and High Court appeals: under Practice Direction 52B, paragraph 8.3, a skeleton argument is filed only where the complexity of the issues justifies one, or where it would assist the court in ways not readily apparent from the papers — it is not automatic.
• Court of Appeal: under Practice Direction 52C, a skeleton argument is a standard part of the appellant's notice, and a respondent who files a respondent's notice must lodge one within 14 days of doing so.
• Court of Appeal page limit: a skeleton must not normally exceed 25 pages, excluding front and back sheets, printed on A4 in at least 12-point font with 1.5 line spacing (PD 52C, paragraph 31).
• Default deadline to appeal: the appellant's notice must be filed within 21 days of the decision under appeal, unless the lower court directed a different period at the hearing (CPR rule 52.12(2)).
• Grounds of appeal vs skeleton argument: the grounds say what was wrong with the decision; the reasons why belong only in the skeleton argument, never in the grounds themselves (PD 52C, paragraph 5(2)).
• Non-compliant skeletons: a Court of Appeal skeleton that breaches the format rules is returned unfiled by the Civil Appeals Office, and the court may refuse to hear argument on any point not included in a skeleton filed on time (PD 52C, paragraph 31).

What is Form N163?

Form N163 is the court form used to lodge a skeleton argument in a civil appeal. A skeleton argument is a concise written summary of the legal and factual arguments a party intends to make at the appeal hearing — it signposts the court to the core issues, the grounds being relied on, and the authorities or evidence that support the party's position, rather than setting out submissions in full.

The form itself captures administrative details — the parties, the case reference, the court dealing with the appeal, and who is representing each side — while the skeleton argument sits alongside as the substantive content. Both appellants and respondents may need to file one, depending on the court and the directions given.

This guide covers appeals in England and Wales. It does not cover criminal appeals against sentence or conviction, which follow a different procedure.

Which appeal regime applies to you?

The single most important thing to establish before drafting anything is which court is hearing your appeal, because that determines which Practice Direction governs your skeleton argument. Two regimes sit underneath the general content rules in Practice Direction 52A:

| | County Court / High Court appeals | Court of Appeal | |---|---|---| | Governing Practice Direction | PD 52B | PD 52C | | Is a skeleton argument required? | Discretionary — filed only where the complexity of the issues justifies it, or it would assist the court in ways not apparent from the papers (para 8.3) | Effectively standard — filed with the appellant's notice; a respondent's notice triggers a mandatory skeleton within 14 days | | Fixed page or format limit? | None set out in PD 52B itself | Not normally more than 25 pages, A4, 12-point font minimum, 1.5 line spacing (para 31) | | Detailed filing timetable? | Case-managed on a discretionary basis; late documents should be added to the appeal bundle at least 7 days before the hearing (para 6.6) | A detailed, dated timetable runs from the "listing window notification" (para 21) | | Appellant's notice form | N161 (or N164 for small claims) | N161 |

Appeals within the County Court (District Judge to Circuit Judge), from the County Court to the High Court, and within the High Court are all covered by PD 52B. Appeals to the Court of Appeal — whether from the High Court, the County Court on a second appeal, or certain first-instance decisions — are covered by the far more prescriptive PD 52C. If you are unsure which applies, check the order or directions you received, or GOV.UK's guidance on which court or tribunal to appeal to.

What every skeleton argument must contain

Whichever court you are appealing to, Section V of Practice Direction 52A sets the baseline content rules for the document itself. A skeleton argument must:

• be concise;
• define and confine the areas of controversy;
• be set out in numbered paragraphs;
• be cross-referenced to any relevant document in the bundle;
• be self-contained — it must not incorporate material from previous skeleton arguments by reference; and
• not include extensive quotations from documents or authorities.

Any documents relied on must be identified. Where an authority is cited, the skeleton must state the proposition of law the authority demonstrates and identify the parts of the authority that support it — and if more than one authority is cited for the same proposition, the skeleton must briefly explain why. The parties should also consider whether the court will need a list of persons featuring in the case, a glossary of technical terms, or a chronology of events (the latter is described as necessary in most appeals). Any statement of costs must show the amount claimed for the skeleton argument separately.

Non-compliance has a direct cost consequence: the cost of preparing a skeleton argument that breaches these requirements, or that was filed outside the applicable time limit, will not be allowed on assessment except as the court directs (PD 52A, paragraph 5.1(5)).

Court of Appeal format rules: the 25-page limit

If your appeal is going to the Court of Appeal, paragraph 31 of Practice Direction 52C adds firm formatting requirements on top of the PD 52A content rules:

| Requirement | Rule | |---|---| | Length | Must not normally exceed 25 pages, excluding front and back sheets | | Paper size | A4 | | Font size | Not less than 12 point | | Line spacing | 1.5 (including footnotes) | | Labelling | Must be labelled as applicable — e.g. appellant's PTA skeleton, appellant's replacement skeleton, respondent's supplementary skeleton — and dated on its front sheet |

A skeleton argument that does not comply with these requirements will be returned to its author by the Civil Appeals Office and may not be re-filed until it does comply. If it is re-filed out of time, it must still be served on all other parties, and the party re-filing it must apply under CPR Part 23 for the court's permission to rely on it before the hearing.

Practice Direction 52B, which governs County Court and High Court appeals, does not set an equivalent numeric page limit — but the "concise" requirement in PD 52A still applies, and an over-long skeleton risks the same costs sanction.

Filing deadlines: when is a skeleton argument due?

Deadlines depend heavily on which court you are in and what stage the appeal has reached. The table below sets out the deadlines that are actually stated in the rules — always check any directions specific to your case, as the court can vary these.

| Step | Deadline | Source | |---|---|---| | File the appellant's notice | Within 21 days of the decision under appeal, unless the lower court directed a different period at the hearing | CPR rule 52.12(2) | | Court of Appeal: skeleton with the appellant's notice | Filed as part of the documents accompanying the appellant's notice where permission has already been granted or is not required | PD 52C, para 3(4)(g) | | Court of Appeal: appellant's permission-stage skeleton served on the respondent | At the same time as the appellant's notice, or when it is filed with the court if later | PD 52C, para 7.1A | | Court of Appeal: respondent's skeleton (respondent's notice filed) | Within 14 days of filing the respondent's notice | PD 52C, para 9 | | Court of Appeal: respondent's skeleton (no respondent's notice, but respondent wishes to address the court) | 35 days after the date of the listing window notification | PD 52C, para 13 and the Timetable at para 21 | | Court of Appeal: appeal skeleton once a hearing is listed | 14 days after the date of the listing window notification | PD 52C, para 21, Timetable Part 1 | | Court of Appeal: replacement skeletons cross-referenced to the final bundle | 70 days after the date of the listing window notification | PD 52C, para 21, Timetable Part 1 | | Court of Appeal: supplementary skeleton argument | As soon as practicable, with the court's permission; only exceptionally allowed if lodged later than 7 days before the hearing | PD 52C, para 32 | | County Court / High Court: any skeleton argument, respondent's notice, or other late document | Added to the appeal bundle as soon as practicable and no less than 7 days before the hearing | PD 52B, para 6.6 |

Grounds of appeal and the skeleton argument are not the same document

Under rule 52.21(3) of the Civil Procedure Rules, an appeal court will only allow an appeal where the decision of the lower court was wrong, or unjust because of a serious procedural or other irregularity. Both the grounds of appeal and the skeleton argument relate to that test — but the Practice Directions are explicit that they play different roles.

The grounds of appeal, filed on a separate sheet with the appellant's notice, must identify as concisely as possible the respects in which the decision is said to be wrong or unjust (PD 52B, para 4.2(d); PD 52C, para 5(1)). Paragraph 5(2) of PD 52C then draws the line sharply: the reasons why the decision was wrong or unjust "must not be included in the grounds of appeal and must be confined to the skeleton argument." In other words, the grounds state the conclusion; the skeleton argument does the persuading.

Worked example: two different skeleton argument timelines

County Court appeal. Priya, a fictional litigant, is appealing a District Judge's decision to a Circuit Judge in the County Court. She files her appellant's notice (Form N161) within the 21-day default period under CPR 52.12(2). Because her case does not raise unusually complex issues, and the court has not directed otherwise, she is not automatically required to file a skeleton argument under PD 52B, paragraph 8.3 — but her advocate decides one would help the court follow a slightly technical limitation-period point, so they prepare and file a short skeleton alongside the appeal bundle, well before the hearing.

Court of Appeal case. Tom, a fictional appellant, has been granted permission to appeal to the Court of Appeal. His appellant's skeleton argument was filed with his appellant's notice under PD 52C, paragraph 3(4)(g). Once the Civil Appeals Office sends the listing window notification, Tom's solicitors know they must serve their appeal skeleton argument (or confirm reliance on the earlier permission-stage skeleton) within 14 days, and that any replacement skeleton cross-referenced to the final hearing bundle is due 70 days after that notification. His skeleton must not exceed 25 pages — if it does, the Civil Appeals Office will simply return it, and he will need to shorten it and re-file before the court will accept it.

What happens if your skeleton argument doesn't comply

The Practice Directions set out real, specific consequences rather than a vague risk of losing the appeal outright:

• Costs are disallowed. Under PD 52A, the cost of preparing a skeleton argument that breaches the content rules, or that was filed late, will not be allowed on assessment except as the court directs.
• The court can refuse to hear the point. Under PD 52C, paragraph 31(4), at the Court of Appeal hearing the court may refuse to hear argument on a point that was not included in a skeleton argument filed within the prescribed time.
• Non-compliant Court of Appeal skeletons are returned unfiled. A skeleton that breaches the 25-page, formatting, or labelling rules in PD 52C, paragraph 31, is returned by the Civil Appeals Office and cannot be relied on until it is corrected and, if filed late, the court gives permission to rely on it.

Because these consequences attach directly to the party who missed the requirement, it is worth treating the applicable Practice Direction as a checklist rather than background reading.

How to use Form N163: step by step

1. Work out which Practice Direction applies. Check the order or directions from your appeal to confirm whether you are appealing within the County Court, from the County Court to the High Court, within the High Court, or to the Court of Appeal. This determines whether PD 52B or PD 52C governs your skeleton argument, and whether one is required at all. See our guide to County Court forms if you are still working out which forms your appeal needs.
2. Check the court's directions for deadlines. Before drafting anything, read any directions the court has issued carefully. These will often specify the deadline for filing the skeleton argument, whether it must be served on the other side, and — in the Court of Appeal — where you sit on the timetable at PD 52C, paragraph 21.
3. Complete the administrative details on Form N163. Fill in your name, address, and contact information, along with the case reference and the court dealing with the appeal. Indicate whether you are the appellant or the respondent, and identify your status in the original proceedings. If you have a solicitor or advocate acting for you, include their details. Our plain-English glossary of County Court terms explains terms such as "appellant" and "respondent" if you are unsure which applies to you.
4. Draft the skeleton argument itself. Set out the grounds of appeal in numbered paragraphs, explaining why the original decision was wrong or unjust, referring to the relevant legal principles, statutory provisions, or case law. Keep the reasons — the "why" — in the skeleton, not in the grounds of appeal document itself, per PD 52C, paragraph 5(2). Keep the language plain and the structure logical.
5. Apply the format and content rules for your court. Follow the PD 52A content rules in every case. If you are in the Court of Appeal, also check your skeleton against the PD 52C, paragraph 31 requirements — page count, font size, line spacing, and labelling — before you file it, so it is not returned unfiled by the Civil Appeals Office.
6. Sign, file, and serve the documents on time. Either you or your legal representative should sign the skeleton argument. Lodge Form N163 and the skeleton with the correct court office by the deadline, and serve a copy on the other parties as required. Keep proof of filing and service in case any question arises later about whether the deadline was met.

This guide provides general information about Form N163 and the skeleton argument rules governing civil appeals in England and Wales. It is not legal advice and is not a substitute for advice tailored to your specific circumstances. The law described was accurate as at August 2026 and is subject to change — always check GOV.UK and justice.gov.uk for the most current position.

Last reviewed: August 2026 by a non-practising solicitor · Next review due: August 2027 or on legislative change.