GOV.UK has no separate "how to complete" page for the N181. The guidance is printed on the form, and this section follows the form in order. Have your claim number and court name to hand.
Top of the form
Name of court and claim number, then boxes for whether the form is completed by, or on behalf of, the claimant, defendant or party, and whether that party is the first, second or third in the claim. A further box is for a legal representative. The form says to note the date by which it must be returned and the court it goes to, which may differ from the court where the proceedings were issued.
Section A, Settlement
The form says parties should make every effort to settle before the hearing, for example by discussion, negotiation or mediation, and that the court will want to know what steps have been taken. It says answers may be considered when the court deals with costs (Civil Procedure Rules Part 44). A1 asks whether you want to attempt to settle at this stage and, if so, whether you want a one month stay. If No, it asks for your reasons. A note says the court may order a stay whether or not the other parties agree, and that you must still complete the rest of the questionnaire. A separate confirmation box is marked "For legal representatives only".
Section B, Court
B1 applies to High Court claims only: whether you consider the claim should remain in the High Court, or which County Court hearing centre you prefer. B2 applies to all cases: whether there is any reason the claim needs to be heard at a particular court or hearing centre, and if so which and why.
Section C, Pre-action protocols
C1 asks whether you have complied fully with the relevant pre-action protocol. If No, it asks why not, or why only partly. A note says the court expects this before a claim starts.
Section D, Case management information
- ✓D1: whether you have made any applications in the claim, and when they are for hearing.
- ✓D2: the track the case should be allocated to (Fast Track, Intermediate Track or Multi-track).
- ✓D3: whether that is agreed with the other party, and if not, brief reasons.
- ✓D4: for the fast and intermediate tracks only, the complexity band (1 to 4, or Not applicable with an explanation). A note says bands run in ascending order of allowable costs.
- ✓D5 and D6: whether the band is agreed, and brief reasons for the proposed band.
- ✓D7 and D8: for the multi-track only, whether you have reached agreement about disclosure of electronic documents, and if not, the issues the court needs to address.
- ✓D9: what directions are proposed for disclosure of non-electronic documents (all cases).
- ✓D10 and D11: for multi-track cases except personal injury, whether you have filed and served a disclosure report (form N263), and whether you have agreed a disclosure proposal.
Section E, Experts
E1: whether you wish to use expert evidence at the trial or final hearing. E2: whether you have copied any expert reports to the other parties. E3: whether you consider the case suitable for a single joint expert. E4: a table listing the expert's name, field of expertise, and justification with an estimate of costs. A note says there is no presumption that expert evidence is necessary, and the court requires a short explanation of your proposals.
Section F, Witnesses
F1: which witnesses of fact you intend to call at the trial or final hearing, including yourself where appropriate. The form then sets out rules on use of the Welsh language for witness evidence, for legally represented and unrepresented parties.
Section G, Trial or final hearing
G1: how long you estimate it will take, in days and hours, or more than three days. G2: whether there are days in the next 12 months when you, an expert or an essential witness cannot attend, with a table of names and dates. The form says to tell the court immediately if these dates change, and, in a note, if your time estimate changes.
Section H, Costs
The form says not to complete this section if you have no legal representative or the case is subject to fixed costs. For a claim likely to be allocated to the multi-track, it says Precedent H must be filed in accordance with CPR 3.13, and the section has a box confirming it is attached.
Section I, Other information
I1: whether you intend to make any applications in the future. I2: any other information you consider will help the judge manage the claim. I3: whether you or a witness are vulnerable in any way the court needs to consider, and what steps, support or adjustments you want considered.
Section J, Directions
The form says you must attempt to agree proposed directions with all other parties, and that a draft of the order for directions you seek must accompany the form, whether agreed or not. It says multi-track directions must be based on the directions published on the justice.gov.uk site, and fast and intermediate track directions on CPR Part 28.
Signature
A signature box, a date, and a box for a legal representative for the first, second or third party, then your name and postal address. Page 12 has phone, DX number, your reference and email, marked "If applicable".
