What should I include in my witness statement?
Generally your statement should contain the facts as you know them.
your statement should include all information you want to rely upon in support of your claim. A failure to mention something may result in the tribunal not having enough evidence before them to make a conclusion on an issue, and if there is no evidence of a point in your statement you cannot introduce that evidence as part of your closing submission.
The requirement that your evidence must be full has two important points to highlight:
Brief Quotes, not long arguments
Only include short, accurate quotations of important exchanges ("X said, 'You're fired.'"). Don't use statements to argue legal points—that's for submissions that occur at the end of the hearing. For example:
"On 12 September 2023, I emailed HR requesting clarification on my notice period (Bundle p15). HR replied on 15 September confirming my notice would end on 30 September 2023 (Bundle p 18). This surprised me as I had a longer notice period."
Personal Knowledge vs Information from Others
If you rely on information from someone else (e.g., a colleague), make this clear: "I was told by X that…"
Where this sits in a claim
Take this further
If this helped and you want more than the free guide, there are two ways to go further: