Agreed chronologies in litigation

What an agreed chronology is

Qatar's international court describes a chronology as a reference point to key events, for use at hearings and to keep events and issues clear ⁴. New Zealand's Ministry of Justice describes it as a document outlining the key events, not every event, and the facts a party intends to establish at trial ⁵.

Agreement is the aim but not always the result. The rules below show two ways of handling disagreement. One marks disputed entries inside a single agreed table ⁴. The other merges each side's chronology and flags what is agreed and what is disputed ⁵.

England and Wales

Practice Direction 29 covers the multi-track. Paragraph 5.7 says a case summary should be designed to assist the court, should set out a brief chronology of the claim, the issues of fact which are agreed or in dispute and the evidence needed to decide them, should not normally exceed 500 words, and should be prepared by the claimant and agreed with the other parties if possible ¹.

For appeals to the Court of Appeal, Practice Direction 52C requires supplementary and unagreed documents bundles to be in chronological order. Core bundles are exempt from that rule ².

The Commercial Court Guide, eleventh edition, has a section headed Chronologies, indices and dramatis personae and an appendix headed Preparation of Chronologies and Indices ³.

Qatar International Court

The Qatar International Court issued Guidance on Chronologies and Dramatis Personae in April 2023 ⁴. It says the court will likely ask for both documents in each case going to trial, except Small Claims ⁴.

• The chronology should be agreed between the parties and should be no longer than is necessary ⁴.
• Agreed facts go in, so the court knows what is common ground ⁴.
• Disagreements are shown in neutral terms, with the competing versions shortly stated ⁴.
• The chronology is a table of at least four columns, from left to right: Date, Facts or Event, Disputes, and E-Bundle reference ⁴.
• The dramatis personae can be a two-column table of name and description ⁴.

New Zealand High Court

For Ordinary Proceedings filed after 1 January 2026, or where a judge orders it, the Ministry of Justice guide sets a staged process ⁵.

Each chronology entry must link to the documents that support it, under High Court Rule 7.4(4) ⁵. The plaintiff serves a draft within 25 working days of the defendant's statement of defence, and the defendant responds within 45 working days of receiving it ⁵.

The merged chronology combines all parties' final chronologies and shows which entries are agreed and which are disputed. The plaintiff prepares it, subject to any other court order. It is filed and served no later than 15 working days after the common bundle is served, or by a date set by the court, under Rule 9.9 ⁵.

High Court of Australia

On appeal, the High Court of Australia uses a form headed Appellant's Chronology ⁶. Part I is a certification that the chronology is in a form suitable for publication on the Internet. Part II is a list of principal events leading to the litigation, with references to the appeal book for findings of fact and evidence ⁶. The form is signed by the senior legal practitioner presenting the case, or by a self-represented appellant ⁶.

Common features