Most medical experts will recognise the other kind of bundle too. Several large scans run together, GP and hospital records out of step with each other, letters copied three times over, and a gap somewhere in the middle that only shows up on the fourth read. This guide sets out what a well-organised bundle looks like from the expert's side, and why it matters under the rules experts already work to.
Why does the state of the bundle matter to a medical expert?
Because the report is only as sound as the record behind it. Practice Direction 35 says experts should consider all material facts, including those which might detract from their opinions (paragraph 2.3). Their report must also give details of the material relied on in making it (paragraph 3.2). Both are harder to do well when the record arrives out of order or incomplete.
The Civil Justice Council's Guidance for the Instruction of Experts in Civil Claims goes a step further. It says experts should try to make sure they have access to all relevant information held by the parties, check that other experts in the same discipline have received the same material, and tell the instructing solicitors about any omissions soon after accepting instructions (paragraph 30).
This is a real, day-to-day issue for experts. In the Bond Solon Expert Witness Survey 2025, not being given all the relevant documents was one of the most common complaints experts had about instructing solicitors, second only to late payment.
There is a practical side as well. Every hour spent putting pages in order is an hour not spent reading the record properly and forming an opinion.
What should an organised medical records bundle include?
Here is a checklist of what an organised bundle should give a medical expert before the work starts. It applies whoever prepares the bundle, whether that is the instructing firm, a records partner or the expert's own team.
1. Every page in strict date order
Entries should run from the earliest to the latest across the whole record, not in separate runs for each provider. Reading a medical history in the order it happened is the quickest way to follow how a condition developed and what was done at each point.
2. Every page dated and numbered
A date and a page number on every page lets the expert refer to an entry precisely and check that nothing has slipped out of sequence. It also makes conversations with the instructing solicitor much simpler, because everyone is looking at the same page.
3. Records from every provider in one sequence
A single claim can involve GP records, hospital notes, clinic letters, test results and records from other providers. In an organised bundle these sit together in date order, so a referral letter sits next to the appointment that followed it and a test result sits next to the consultation that discussed it.
4. Duplicates and blank pages easy to identify, with nothing removed
Medical records often contain several copies of the same letter, sent to the GP, the hospital and the patient. In an organised bundle, duplicates and blank pages are easy to spot but stay in the bundle. Nothing is taken out, so the bundle still matches the record that was disclosed and the expert decides what matters.
5. Legible pages
The Pre-Action Protocol for the Resolution of Clinical Disputes refers to legible copies of the claimant's records (paragraph 3.5). Pages should be the right way up and readable. Where a page genuinely cannot be read, it is better flagged early than left for the expert to discover halfway through a report.
6. Searchable, including handwritten notes
A searchable bundle lets the expert go straight to a condition, a provider or a date without reading page by page. Search is most useful when it also covers scanned and handwritten entries, which is where much of the detail in older GP and hospital records sits.
7. A clear record of what was sent
The Civil Justice Council guidance says all material sent to an expert should be listed, with dates, in the report or an appendix (paragraph 55). When the instructions set out exactly what has been provided, that list is far easier to put together accurately.
8. Gaps visible and raised early
Date order makes gaps much easier to see, for example a year with no GP entries, or a hospital admission with no discharge letter. Under the Civil Justice Council guidance, the expert should tell the instructing solicitors about omissions soon after accepting instructions. If information is still not available, CPR 35.14 allows experts to ask the court for directions to help them carry out their work.
What should an organised bundle not do?
An organised bundle should not interpret the record. Putting pages in order is a different job from deciding which entries matter, and that second job belongs to the expert. The bundle should not pick out the relevant entries, draw conclusions or leave pages out on the expert's behalf.
This matters because the opinion in the report has to be the expert's own. A well-organised bundle saves time on the groundwork and leaves the clinical reading and judgement exactly where they should be.
Is an organised bundle the same as a paginated bundle?
Not quite. In clinical negligence claims, the Pre-Action Protocol expects the records to be placed in a paginated bundle at the earliest opportunity and kept up to date (paragraph 3.5). Full pagination is a more formal step, usually carried out by pagination firms or in-house legal teams once the records are complete. An organised, pre-sorted bundle is often the starting point for it. We explain the difference in more detail in Pre-sorting, indexing and pagination: what each step does to a medical record.
| Comparison | Organised (pre-sorted) bundle | Fully paginated bundle |
|---|---|---|
| What it gives the expert | Every page in strict date order, dated, numbered and searchable | Pages numbered in sequence, arranged in sections, with a detailed contents list |
| When it is used | As soon as records arrive, for early review and day-to-day work | Later, when a paginated bundle is needed for proceedings |
| Who usually prepares it | A records sorting service, the instructing firm or the expert's team | Pagination firms or in-house legal teams |
How Sortal helps medical experts
Sortal returns an organised record built around this checklist. Records can be forwarded by the expert or sent straight from the instructing firm. Each page is read, dated and placed in strict date order, every page is numbered, and the whole bundle is searchable by condition, provider or date, including handwritten notes. You can see each stage in how it works.
Duplicates and blank pages stay in the bundle and are easy to identify. Our team checks every bundle before it is returned, so it is ready to work from straight away.
Sortal does not paginate, draw clinical conclusions or remove anything. Your opinion is never touched. AI is used to organise the pages, and the reading and judgement stay with you. Sortal fits around your existing process, whether you receive instructions directly or through a reporting organisation. Find out more about our services.
Key points
In short
- An organised bundle puts every page in strict date order, dated and numbered, across all providers.
- Duplicates and blank pages should be easy to identify, not removed.
- Searchable pages, including handwritten notes, save reading page by page.
- PD35 and the Civil Justice Council guidance expect experts to consider all material facts, list what they relied on and raise omissions early.
- Organising the record supports the expert. The opinion stays entirely with them.
Frequently asked questions
Can a medical expert turn down instructions if the records are not sorted?
Yes, and it happens. Guidance from the patient safety charity AvMA for people bringing clinical negligence claims notes that, in many cases, medical experts will reject instructions if the medical records are not sorted. Whether to accept an instruction is always the expert's own decision.
Who is responsible for providing the medical records to the expert?
The party instructing the expert. The Civil Justice Council guidance says those instructing experts should give clear instructions and attach the relevant documents. In clinical negligence claims, the Pre-Action Protocol places the job of putting the claimant's records into a bundle with the claimant's side.
What happens if updated documents arrive after the expert has started?
The Civil Justice Council guidance says that when further documents are sent before a report is finalised, the solicitor must tell the expert whether any witness statements or expert reports are updated versions of those sent earlier, and whether they have been filed and served.
Who is an expert's report written for?
The court. Practice Direction 35 says a report should be addressed to the court, not to the party who gave the instructions, and that expert evidence should be the independent product of the expert, uninfluenced by the pressures of litigation.
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- Practice Direction 35, Experts and Assessors, paragraphs 2.1, 2.3, 3.1 and 3.2: justice.gov.uk
- Civil Procedure Rules Part 35, rule 35.14: justice.gov.uk
- Civil Justice Council, Guidance for the Instruction of Experts in Civil Claims (2014), paragraphs 20, 30, 31 and 55: judiciary.uk
- Pre-Action Protocol for the Resolution of Clinical Disputes, paragraph 3.5: justice.gov.uk
- Bond Solon, Expert Witness Survey 2025: bondsolon.com
- AvMA, Clinical negligence claims: litigants in person (page 5): avma.org.uk
This article is general information for medical experts and is not legal advice. Last reviewed .